Disallowance of expenditure on non deduction of TDS u/s 194Q

Assessee fails to deduct TDS on payment made to purchases u/s 194 Q exceeding 50 lakhs. He obtained Form 26A (from their CA ) from few parties. Assessing officer propose to make addition us/s 40 a (ia) of the Act for the remaining amount. Assessee submitted all the purchase bills supported by the bank statement for the payment. And also GSTR 2A & 2B and Annual return table 8 as evidence for the purchase payment along with e-way bill Kindly give your opinion and any case laws in favour of my assessee.

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