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    <title>2012 (11) TMI 1163 - ITAT PUNE</title>
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    <description>Section 40(a)(ia) was treated as applying only to amounts remaining payable at the end of the relevant previous year, rather than sums already paid during that year without tax deduction at source. Where payment to the hospital had been made and no liability remained outstanding at year-end, the disallowance was considered unsustainable. The addition was therefore deleted, providing relief to the assessee on the substantive issue.</description>
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      <description>Section 40(a)(ia) was treated as applying only to amounts remaining payable at the end of the relevant previous year, rather than sums already paid during that year without tax deduction at source. Where payment to the hospital had been made and no liability remained outstanding at year-end, the disallowance was considered unsustainable. The addition was therefore deleted, providing relief to the assessee on the substantive issue.</description>
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