The Tribunal held that the sole purpose of section 40(a)(ia) was to put a check on payments made by an assessee. Thus, it cannot be said that when the assessee has deducted tax at a different rate, the shortfall in deduction of tax, disallowance cannot be made. Interest can be revered for shortfall of the amount. (AY.2013-14)
M. V. A. Seetharama Raju v. Dy. CIT (2022) 97 ITR 714 (Chennai) (Trib)
S. 40(a)(ia): Amounts not deductible-Deduction at source-Shortfall of amount deducted-Not tantamount to non-deduction tion Cannot be disallowed-Recovery of shortfall with interest-disallowance not justified. [S. 194A, 201(1), 201(IA)]