In the result, both the appeals filed by assessee stands allowed for statistical purposes
Bench: Shri. Chandra Poojari & Smt. Beena Pillai
u/s. 201(1A). In our considerate view, the assessee(deductor) gets exonerated from the applicability of TDS provisions on disallowance of the expenditure in question under section 40(a)(i)/(ia) of the Act. This rational is based on the scheme of Section 40(a)(i)/(ia), which is aimed at ensuring that an expenditure should not be allowed