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The ITAT addressed TDS liability on year-end provisions, finding no short deduction under section 201 for excess provisions not paid to vendors. The tribunal held that interest under section 201(1A) cannot be levied on unpaid excess provisions. For actual payments made in the subsequent year, TDS liability is determined on the actual amount paid (Rs. 24,76,17,968/-), with interest calculated from the year-end provision date (31.03.2015) to the date of actual payment. Following precedent in a similar case, the tribunal deleted the interest on unpaid excess provisions and restricted TDS liability to the actual amount disbursed.
The ITAT addressed TDS liability on year-end provisions, finding no short deduction under section 201 for excess provisions not paid to vendors. The tribunal held that interest under section 201(1A) cannot be levied on unpaid excess provisions. For actual payments made in the subsequent year, TDS liability is determined on the actual amount paid (Rs. 24,76,17,968/-), with interest calculated from the year-end provision date (31.03.2015) to the date of actual payment. Following precedent in a similar case, the tribunal deleted the interest on unpaid excess provisions and restricted TDS liability to the actual amount disbursed.
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