Compliance with binding interim judicial directions requiring a bank not to treat foreign-leg Leave Fare Concession reimbursement as income for tax deduction at source prevents a later declaration of substantive taxability from creating a retrospective deductor default. The reimbursement's taxability and the bank's liability as deductor are distinct. The bank therefore could not be treated as an assessee in default under section 201(1), and consequential interest under section 201(1A) did not survive; the contrary orders were set aside.
Compliance with binding interim judicial directions requiring a bank not to treat foreign-leg Leave Fare Concession reimbursement as income for tax deduction at source prevents a later declaration of substantive taxability from creating a retrospective deductor default. The reimbursement's taxability and the bank's liability as deductor are distinct. The bank therefore could not be treated as an assessee in default under section 201(1), and consequential interest under section 201(1A) did not survive; the contrary orders were set aside.
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