Credit of income to payee's account triggers TDS only when actually credited or paid, not on posting to liability accounts. The timing for withholding under section 194A is tied to payment or the credit of the income to the account of the payee. Posting interest to an 'Interest Payable Account' or 'Liability for Expense Account' under mercantile accounting does not amount to crediting the payee's account and therefore does not trigger the obligation to deduct tax at source until the interest is actually paid or credited to the payee.
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Provisions expressly mentioned in the judgment/order text.
Credit of income to payee's account triggers TDS only when actually credited or paid, not on posting to liability accounts.
The timing for withholding under section 194A is tied to payment or the credit of the income to the account of the payee. Posting interest to an "Interest Payable Account" or "Liability for Expense Account" under mercantile accounting does not amount to crediting the payee's account and therefore does not trigger the obligation to deduct tax at source until the interest is actually paid or credited to the payee.
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