https://www.taxtmi.com/caselaws?id=233872 Section 40(a)(ia) is read as applying to any amount payable to a resident on which tax was deductible at source but was not deducted or not paid within the prescribed time; the provision does not insert an unstated limitation to liabilities outstanding on 31 March. The words "payable" and "paid" are not interchangeable for this purpose, and year-end closing entries do not control the disallowance. The text also rejects the Special Bench view in Merilyn Shipping, holding that clear statutory language cannot be narrowed by relying on draft Bill materials or legislative debates. The stated ratio is that a court must apply the provision as enacted, without adding a temporal condition not found in the text. en-us Thu, 02 May 2013 00:00:00 +0530 Mon, 04 Aug 2025 11:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=233872 Section 40(a)(ia) is read as applying to any amount payable to a resident on which tax was deductible at source but was not deducted or not paid within the prescribed time; the provision does not insert an unstated limitation to liabilities outstanding on 31 March. The words "payable" and "paid" are not interchangeable for this purpose, and year-end closing entries do not control the disallowance. The text also rejects the Special Bench view in Merilyn Shipping, holding that clear statutory language cannot be narrowed by relying on draft Bill materials or legislative debates. The stated ratio is that a court must apply the provision as enacted, without adding a temporal condition not found in the text. Case-Laws Income Tax Thu, 02 May 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=233872