Assessee made payments towards purchase of material and online advertisement and submitted that no TDS was deductible on such payments. Assessing Officer made disallowance of expenses under section 40(a)(ia) on ground that assessee had not deducted tax at source under section 194C  of the Act. Commissioner (Appeals) confirmed disallowance. Tribunal held that as no findings on merits of disallowance had been recorded by Commissioner (Appeals), matter was  set aside  to examine  on merits. General expenses, contention was raised for the first time. Matter was set aside to CIT(A)  (AY.2010-11)