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    <title>2015 (10) TMI 1460 - ITAT PANAJI</title>
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    <description>Interest expenditure disallowed for non-deduction of tax at source was held unsustainable to the extent the recipient had already included the payment in its return and paid tax. The tax deduction mechanism is aimed at protecting revenue, and where the deductee has discharged the tax liability, no revenue loss remains. The second proviso to section 40(a)(ia), read with the first proviso to section 201(1), supports treating the tax as deemed deducted and paid in such circumstances. The addition was therefore deleted in favour of the assessee to the extent of the tax-paid amount.</description>
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      <link>https://www.taxtmi.com/caselaws?id=266185</link>
      <description>Interest expenditure disallowed for non-deduction of tax at source was held unsustainable to the extent the recipient had already included the payment in its return and paid tax. The tax deduction mechanism is aimed at protecting revenue, and where the deductee has discharged the tax liability, no revenue loss remains. The second proviso to section 40(a)(ia), read with the first proviso to section 201(1), supports treating the tax as deemed deducted and paid in such circumstances. The addition was therefore deleted in favour of the assessee to the extent of the tax-paid amount.</description>
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