Held that disallowance of payments for failure to deduct tax at source thereon was to be sustained. The amendment made to the provisions of section 40(a)(ia) of the Act by the Finance (No. 2) Act, 2014 do not have retrospective application. Relied on Shree Choudhary Transport Company v. ITO (2020) 426 ITR 289 (SC). (AY.2009-10)
Dy. CIT v. Daawat Foods Ltd. (2021) 91 ITR 110 (Delhi)(Trib.)
S. 40(a)(ia) : Amounts not deductible-Deduction at source-Amendment by Finance (No. 2) Act, 2014 limiting disallowance to 30 per cent. of sum payable-Cannot be applied to Assessment Year 2009-10-Disallowance sustained.