Held, that for cases of short deduction of tax at source the correct course of action is proceeding under section 201 of the Act, the disallowance under section 40(a)(ia) is deleted. Followed, PCIT v. Future First Info Services P. Ltd.(2022) 447 ITR 299 (Delhi)(HC) (AY. 2007-08, 2008-09)
Joshi Technologies International Inc. v. Asst. CIT (IT) (2024)109 ITR 70 (Ahd)(Trib)
S. 40(a)(ia) : Amounts not deductible-Deduction at source-Shortfall in deduction of tax at source —Disallowance is deleted-Proper course of action was proceeding under section 201[S. 201]
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