Tribunal held that; since the expenditure was only estimated and work would be executed against these expenses in subsequent years, the payee was not known. Hence it was not possible for the assessee to deduct tax at source on the estimated expenditure on work which was to be completed in years to come. The financial statements of a particular project were to be made once in the life of the project, on completion of substantial activity and therefore, the assessee did not have any option but to make estimate for expenses on minor/miscellaneous work. On facts the disallowance made by the Assessing Officer was directed to be deleted based on the fact that the assessee had paid tax at source on or before submission of the return.(AY. 2012-13 )