In the result, the appeals of the assessee are allowed
Bench: Dr. B. R. R. Kumarsh. Anubhav Sharma
section 234E in the statute & relevant to the issue under consideration. The same are reproduced as under: “E. Rationalization of Tax Deduction at Source (TDS) and Tax Collection at Source (TCS) Provisions I. Deemed date of payment of tax by the resident payee ……………………………….(Not reproduced as not relevant) II. Disallowance