Tribunal held that, if there was short deduction, revenue was free to proceed to pass an order u/s 201 of Act, but no disallowance can be made. (AY. 2011-12)
Scrabble Entertainment Ltd. v. ACIT (2018) 169 DTR 51 / 193 TTJ 418 ( Mum.)(Trib.)
S. 40(a)(ia) : Amounts not deductible-Deduction at source -Short deduction of deduction at source–No disallowance can be made. [S.194C, 194J, S. 201]