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ITAT adjudicated a tax dispute concerning TDS liability and provisions reversal. The tribunal determined that voluntary disallowance of expenses under section 40(a)(ia) does not automatically constitute an "assessee in default" under section 201(1). The provisions of sections 40(a)(ia) and 201(1)/201(1A) were deemed mutually exclusive. Consequently, the assessee cannot be treated as in default, and no interest is chargeable under section 201(1A). The tribunal emphasized that no estoppel exists against statutory provisions. Ultimately, the assessee's appeal was allowed, effectively negating potential tax penalties and interest implications.
ITAT adjudicated a tax dispute concerning TDS liability and provisions reversal. The tribunal determined that voluntary disallowance of expenses under section 40(a)(ia) does not automatically constitute an "assessee in default" under section 201(1). The provisions of sections 40(a)(ia) and 201(1)/201(1A) were deemed mutually exclusive. Consequently, the assessee cannot be treated as in default, and no interest is chargeable under section 201(1A). The tribunal emphasized that no estoppel exists against statutory provisions. Ultimately, the assessee's appeal was allowed, effectively negating potential tax penalties and interest implications.
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