Tribunal held that, TDS deposited beyond the due date but before the due date of filing the return of income is an allowable expenditure.  relied in CIT v. Naresh Kumar (2014) 362 ITR 256 (Delhi) (HC) where it has been held that the provisions of S. 40(a)(ia) were to be interpreted liberally and equitably keeping in mind the object and purpose behind the same so that the assessee do not suffer unintended and deleterious consequences and therefore the amendment to S. 40(a)(ia) as made by Finance Act, 2010 was retrospective in nature and therefore the amount of TDS which is deposited late but before due date of filing of return of income enables the assessee to claim the deduction of the expenditure in the concerned year itself.   Accordingly, Tribunal deleted the disallowance. (AY. 2005-06, 2007-08)