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    <title>2015 (3) TMI 451 - ITAT PUNE</title>
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    <description>Section 40(a)(ia) applies to expenditure on which tax was deductible under Chapter XVII-B but was not deducted, or was not paid within the prescribed time, even if the amount was actually paid during the year. The word &quot;payable&quot; was read in its statutory context and not as limiting disallowance only to year-end outstanding balances. The provision was treated as a TDS compliance measure, and the distinction between paid and payable amounts was rejected as unsupported by the text. On that interpretation, the disallowance was sustained and the issue was decided in favour of the Revenue.</description>
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