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    <title>2019 (5) TMI 616 - ITAT DELHI</title>
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    <description>Section 40(a)(ia) was held inapplicable to salary-related TDS payments because salary is outside the statutory categories covered by that disallowance provision, so that addition was deleted. The Finance (No. 2) Act, 2014 amendment reducing the disallowance to 30% was treated as curative, so the harsher 100% disallowance was not sustained where the provision otherwise applied. Where deductees had allegedly offered the receipts to tax and TDS was later deposited, the factual claims required verification by the Assessing Officer to avoid double taxation and to determine the correct year of allowance; the matter was remanded for limited verification and consequential relief.</description>
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      <title>2019 (5) TMI 616 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=379888</link>
      <description>Section 40(a)(ia) was held inapplicable to salary-related TDS payments because salary is outside the statutory categories covered by that disallowance provision, so that addition was deleted. The Finance (No. 2) Act, 2014 amendment reducing the disallowance to 30% was treated as curative, so the harsher 100% disallowance was not sustained where the provision otherwise applied. Where deductees had allegedly offered the receipts to tax and TDS was later deposited, the factual claims required verification by the Assessing Officer to avoid double taxation and to determine the correct year of allowance; the matter was remanded for limited verification and consequential relief.</description>
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