Held that once an amount is disallowed under section 40(a)(i)/(ia), 40(a)(ia) for non-deduction of tax, it cannot be subject to TDS provisions again so as to make assessee liable to interest under section 201(1A). (AY. 2012-13, 2013-14)
Robert Bosch Engineering and Business Solutions (P.) Ltd. v. ITO (2022) 194 ITD 340 (Bang.)(Trib.)
S. 201 : Deduction at source-Failure to deduct or pay-Deducted at the time of payment Amounts not deductible-Deduction at source-Non-resident-Once an amount is disallowed for non-deduction of tax, it cannot be subject to TDS provisions again so as to make assessee liable to interest under section 201(1A) of the Act. [S. 40(ia), 40(a)(ia), 201(1), 201(IA)]