https://www.taxtmi.com/caselaws?id=289565 A bona fide and long-accepted belief that tax was not deductible at source was accepted as a valid basis to resist disallowance under section 40(a)(ia), so the principal disallowance was not sustained on that ground. The amendment limiting disallowance to 30% was treated as a substantive change and applied prospectively only. Disallowance under section 40(a)(ia) was held to extend to both amounts paid during the year and amounts outstanding at year-end, and its operation was not made conditional on a prior order under section 201. The additional ground concerning tax liability borne under section 201 was remanded for fresh factual examination. en-us Thu, 11 May 2017 00:00:00 +0530 Fri, 07 Aug 2020 06:50:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=289565 A bona fide and long-accepted belief that tax was not deductible at source was accepted as a valid basis to resist disallowance under section 40(a)(ia), so the principal disallowance was not sustained on that ground. The amendment limiting disallowance to 30% was treated as a substantive change and applied prospectively only. Disallowance under section 40(a)(ia) was held to extend to both amounts paid during the year and amounts outstanding at year-end, and its operation was not made conditional on a prior order under section 201. The additional ground concerning tax liability borne under section 201 was remanded for fresh factual examination. Case-Laws Income Tax Thu, 11 May 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=289565