Held that once there is  a categorical finding that the assessee had not credited the corresponding liability for expenses to the account of the concerned vendors who had rendered the services, the payees become non-identifiable and hence there was no question of applicability of provisions requiring tax deduction at source thereon. Merely because the assessee had voluntarily disallowed the expenses under section 40(a)(ia) of the Act in the return, they would not automatically enable the Assessing Officer to treat it as assessee in default under section 201(1) of the Act and consequentially levy interest under section 201(1A) of the Act. The provisions of section 40(a)(ia) and section 201(1) and (1A) of the Act are mutually exclusive. In any case, there was no estoppel against the statute. The assessee could not be treated as assessee in default under section 201(1) of the Act and no interest was chargeable under section 201(1A) of the Act.(AY. 2012-13)