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    <title>2016 (4) TMI 164 - ITAT BANGALORE</title>
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    <description>Tax was not deductible at source on year-end provisions that were reversed in the next accounting year because the decisive test was whether income had actually accrued in the payee&#039;s hands. The mere creation of book entries did not by itself establish chargeability to tax, and withholding applies only to sums chargeable to tax. Applying the principle that income tax is levied on real income rather than hypothetical income reflected only in accounts, the absence of actual accrual meant there was no TDS obligation. The assessee therefore could not be treated as an assessee in default under section 201(1).</description>
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      <link>https://www.taxtmi.com/caselaws?id=326050</link>
      <description>Tax was not deductible at source on year-end provisions that were reversed in the next accounting year because the decisive test was whether income had actually accrued in the payee&#039;s hands. The mere creation of book entries did not by itself establish chargeability to tax, and withholding applies only to sums chargeable to tax. Applying the principle that income tax is levied on real income rather than hypothetical income reflected only in accounts, the absence of actual accrual meant there was no TDS obligation. The assessee therefore could not be treated as an assessee in default under section 201(1).</description>
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