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    <title>2017 (6) TMI 1177 - ITAT JAIPUR</title>
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    <description>The appeal was partly allowed for statistical purposes only. The delay in filing the appeal seeking condonation was granted after a 70-day delay. The disallowance of expenses under Section 40(a)(ia) for non-deduction of TDS was upheld based on the interpretation that the liability to deduct TDS arises upon payment. The application of the second proviso to Section 40(a)(ia) was set aside for verification by the Assessing Officer. The issue of retrospective application of the second proviso was referred back for further examination. Grounds related to these issues were restored to the Assessing Officer for verification.</description>
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      <link>https://www.taxtmi.com/caselaws?id=196302</link>
      <description>The appeal was partly allowed for statistical purposes only. The delay in filing the appeal seeking condonation was granted after a 70-day delay. The disallowance of expenses under Section 40(a)(ia) for non-deduction of TDS was upheld based on the interpretation that the liability to deduct TDS arises upon payment. The application of the second proviso to Section 40(a)(ia) was set aside for verification by the Assessing Officer. The issue of retrospective application of the second proviso was referred back for further examination. Grounds related to these issues were restored to the Assessing Officer for verification.</description>
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