The assessee made provision for general expenses, however not claimed as deduction while filing the return. The Assessing Officer initiate proceedings under section 201 and 201(IA) of the Act and treated the assessee as assessee-in default of the amount made provision. The order of the Assessing officer is affirmed by the CIT (A) and Tribunal. On appeal allowing the appeal the Court held that in the absence of any accrual of income, there is no obligation on the part of the assessee to deduct tax at source. Court also held that   the provisions were created during the course of the year and reversal of entry was also made in the same accounting year. The Assessing Officer erred in law in holding that the assessee should have deducted tax at the rate applicable with interest. The Commissioner (Appeals) and the Tribunal were wrong to confirm the order of the Assessing Officer. The assessee was not liable to deduct tax at source. (AY.2012-13)