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of TDS u/s 194I - hire charges paid for the equipment disallowed - addition u/s 40(a)(ia) - the amount of equipment hire charges in question having been already offered to tax by NCC Limited, the assessee-company cannot be treated as assessee in default for non-deduction of tax at source from the said payment and there is no question of making disallowance under section 40(a)(ia). - Matter remanded back to AO for the limited purpose of this verification - AT
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