For AY 2014-15, the assessee deducted tax at source on fees for technical services and lease rent but deposited it belatedly. The AO accepted the assessee’s submission, supported by Form 26A, that the payee had already offered the income and paid taxes, hence no disallowance under section 40(a)(ia) was required. The Principal Commissioner revised the order under section 263, treating the assessee as in default. Held, dismissing the appeal, that once the payee had offered the income and paid tax, the assessee was not in default under section 201(1). Consequently, no disallowance could be made under section 40(a)(ia). The AO’s view was plausible, hence the order was neither erroneous nor prejudicial to Revenue. Revision under section 263 was unjustified.(AY. 2014-15)