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    <title>2012 (11) TMI 1163 - ITAT PUNE</title>
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    <description>Section 40(a)(ia) was treated as a year-end disallowance provision applying to amounts remaining payable, not to sums already paid during the previous year. On that reasoning, where payment to the hospital had been made during the year and nothing was outstanding at 31 March, disallowance for non-deduction of tax at source was not sustainable. The note reflects the Special Bench view that the relevant condition for invoking the provision is the existence of an unpaid liability at year-end, and that an actually paid amount falls outside its scope.</description>
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      <title>2012 (11) TMI 1163 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=180824</link>
      <description>Section 40(a)(ia) was treated as a year-end disallowance provision applying to amounts remaining payable, not to sums already paid during the previous year. On that reasoning, where payment to the hospital had been made during the year and nothing was outstanding at 31 March, disallowance for non-deduction of tax at source was not sustainable. The note reflects the Special Bench view that the relevant condition for invoking the provision is the existence of an unpaid liability at year-end, and that an actually paid amount falls outside its scope.</description>
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      <pubDate>Tue, 20 Nov 2012 00:00:00 +0530</pubDate>
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