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    <title>2015 (8) TMI 760 - ITAT CHENNAI</title>
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    <description>Section 40(a)(ia) was held to apply not only to amounts outstanding at year-end but also to sums paid during the year where tax was deductible at source. The Tribunal reasoned that the obligation to deduct tax arises at the time of payment or credit, and the provision could not be narrowed by reading in a limitation not found in the text. Following the Calcutta and Gujarat High Courts, it rejected the contrary view in Merilyn Shipping and the passing reference in Vector Shipping. The disallowance was therefore upheld.</description>
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      <description>Section 40(a)(ia) was held to apply not only to amounts outstanding at year-end but also to sums paid during the year where tax was deductible at source. The Tribunal reasoned that the obligation to deduct tax arises at the time of payment or credit, and the provision could not be narrowed by reading in a limitation not found in the text. Following the Calcutta and Gujarat High Courts, it rejected the contrary view in Merilyn Shipping and the passing reference in Vector Shipping. The disallowance was therefore upheld.</description>
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