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ITAT adjudicated a TDS dispute under sections 194IA and 195, finding the assessee failed to substantively demonstrate compliance with first proviso to section 201(1). Despite incomplete initial documentation, the tribunal exercised discretion by remanding the case, providing the assessee an additional opportunity to present comprehensive evidence before the Assessing Officer. The appellate order set aside the lower court's decision, restoring all demand-related issues for fresh examination, and technically allowed the assessee's appeal for statistical purposes, thereby preserving procedural fairness while maintaining statutory scrutiny of tax deduction requirements.