If 201 order is settled under VSV and taxes are paid by the deductor, then while computing disputed tax liability for 143(3) order, no disallowance u\/s 40(a)(ia) is to be taken into account. As clarified, benefit of payment under VSV will be available to the deductor in the same year in which section 40(a)(ia) additions are made. However, as per clarifications issued, deductee will get credit of taxes paid by deductor on the date of settlement of dispute and consequentially interest u\/s 234A\/B\/C will be applicable i.e. where 201 order for FY 2015-16 is settled by in FY 2019-20 by the deductor, then deductee will be required to pay interest u\/s 234A\/B\/C till FY 19-20. Is this not a hardship caused to deductee, without being at fault?<\/p>\n","protected":false},"excerpt":{"rendered":"
If 201 order is settled under VSV and taxes are paid by the deductor, then while computing disputed tax liability for 143(3) order, no disallowance u\/s 40(a)(ia) is to be taken into account. As clarified, benefit of payment under VSV will be available to the deductor in the same year in which section 40(a)(ia) additions are made. However, as per clarifications issued, deductee will get credit of taxes paid by deductor on the date of settlement of dispute and consequentially interest u\/s 234A\/B\/C will be applicable i.e. where 201 order for FY 2015-16 is settled by in FY 2019-20 by the deductor, then deductee will be required to pay interest u\/s 234A\/B\/C till FY 19-20. Is this not a hardship caused to deductee, without being at fault?<\/p>\n