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The liability u/s 201(1) for TDS on provisions in books of accounts was disputed by the assessee, arguing that the provisions were reversed in a subsequent year and TDS was complied with when actual invoices were booked. The appellate authority, considering the Assessee's contention and precedent of IBM India (P) Ltd., held that if TDS was deducted in a later year, demand u/s 201(1) cannot be raised, with interest u/s 201(1A) applicable only until deduction. The CIT(A) correctly granted relief on TDS payment, directing the AO to calculate interest until deduction. Revenue's appeals were dismissed by ITAT.
The liability u/s 201(1) for TDS on provisions in books of accounts was disputed by the assessee, arguing that the provisions were reversed in a subsequent year and TDS was complied with when actual invoices were booked. The appellate authority, considering the Assessee's contention and precedent of IBM India (P) Ltd., held that if TDS was deducted in a later year, demand u/s 201(1) cannot be raised, with interest u/s 201(1A) applicable only until deduction. The CIT(A) correctly granted relief on TDS payment, directing the AO to calculate interest until deduction. Revenue's appeals were dismissed by ITAT.
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