Assessee, an Indian company, was engaged as a stock broker. Assessee sold shares on behalf of an overseas depository and sent remittance to said depository. Assessing Officer held that TDS should have been deducted on payments made by payer  and computed tax liability on non-deduction of tax at source and further computed tax withholding demand, including interest for delay in payment. CIT(A) affirmed the order of the Assessing Officer. On appeal the Tribunal held that  deduction at source liability under section 201 being a vicarious liability of payer of an income, would not come into play when primary liability of recipient of income was already discharged. On facts since taxes were paid as advance tax by overseas depository on capital gains of said shares, to that extent, assessee tax-deductor could not be saddled with a tax withholding demand under section 201(1) read with section 195 and thus, basic tax withholding liability under section 201(1) is  quashed and interest liability under section 201(1A), being consequential in nature also quashed. (AY. 2015-16 )