https://www.taxtmi.com/caselaws?id=418085 Year-end provisions are not to be treated as a TDS default under section 201(1) where tax is later deducted and remitted on receipt of invoices, and interest under section 201(1A) cannot be sustained on that portion. The section 201 scheme is a recovery mechanism linked to a real revenue loss, while disallowance under section 40(a)(i)/(ia) operates separately as a compliance consequence and prevents repeated TDS exposure on amounts already disallowed. For provisions reversed because invoices were never received, further verification is required, including whether the recipient has already paid tax on the embedded income before interest can be levied. en-us Mon, 31 Jan 2022 00:00:00 +0530 Mon, 07 Feb 2022 11:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=418085 Year-end provisions are not to be treated as a TDS default under section 201(1) where tax is later deducted and remitted on receipt of invoices, and interest under section 201(1A) cannot be sustained on that portion. The section 201 scheme is a recovery mechanism linked to a real revenue loss, while disallowance under section 40(a)(i)/(ia) operates separately as a compliance consequence and prevents repeated TDS exposure on amounts already disallowed. For provisions reversed because invoices were never received, further verification is required, including whether the recipient has already paid tax on the embedded income before interest can be levied. Case-Laws Income Tax Mon, 31 Jan 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=418085