In the result, grounds of appeal raised by the assessee are allowed
Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay
disallowance u/s 40(a)(ia) has been made by Assessing Officer, in assessment proceedings, the same amount could not be considered as an amount covered by provisions of section 194A so as to raise TDS demand under section 201 or to impose penalty u/s 271C for default of non-deduction of TDS. 3. For that Ld. CIT(A) erred