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of Disallowance u/s 40(a)(ia) with regard to the non-deduction of tax at source in respect of payments made towards labour payment - Once the recipient has disclosed the payment in his return of income, the assessee is not liable for TDS. - Just because the recipient / contractor filed his return of income for the AYs 2013-14 and 2014-15 belatedly, it is not correct to disallow the payment made by the assessee. - AT
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