https://www.taxtmi.com/caselaws?id=779177 ITAT, Delhi (AT) upheld disallowance under s.40(a)(ia), holding it applies to both paid and payable expenditures in line with SC precedent. The tribunal affirmed disallowance where the assessee failed to demonstrate that payments were not subject to TDS. An additional/revised ground that TDS was in fact deducted was restored to the AO for factual verification, with the assessee given three opportunities to plead and prove relevant facts. The plea relying on the s.40(a)(ia) proviso (Finance Act, 2012) was rejected for failure to produce the requisite payee accountant certificates. en-us Tue, 21 Jan 2025 00:00:00 +0530 Tue, 30 Sep 2025 08:30:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779177 ITAT, Delhi (AT) upheld disallowance under s.40(a)(ia), holding it applies to both paid and payable expenditures in line with SC precedent. The tribunal affirmed disallowance where the assessee failed to demonstrate that payments were not subject to TDS. An additional/revised ground that TDS was in fact deducted was restored to the AO for factual verification, with the assessee given three opportunities to plead and prove relevant facts. The plea relying on the s.40(a)(ia) proviso (Finance Act, 2012) was rejected for failure to produce the requisite payee accountant certificates. Case-Laws Income Tax Tue, 21 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779177