https://www.taxtmi.com/caselaws?id=787225 The note addresses whether a voluntary suo moto disallowance under Section 40(a)(ia) for year end provisions, where payees were not identifiable, gives rise to an obligation to deduct TDS and renders the taxpayer an assessee in default under Section 201(1) with interest under Section 201(1A). It records that where payees are not identifiable at year end there is no legal obligation to deduct TDS and no disallowance under Section 40(a)(ia) for such provisions; consequently treating the disallowance as creating default and levying interest was not sustained and the appeal succeeded. en-us Wed, 25 Feb 2026 00:00:00 +0530 Sat, 28 Feb 2026 08:41:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787225 The note addresses whether a voluntary suo moto disallowance under Section 40(a)(ia) for year end provisions, where payees were not identifiable, gives rise to an obligation to deduct TDS and renders the taxpayer an assessee in default under Section 201(1) with interest under Section 201(1A). It records that where payees are not identifiable at year end there is no legal obligation to deduct TDS and no disallowance under Section 40(a)(ia) for such provisions; consequently treating the disallowance as creating default and levying interest was not sustained and the appeal succeeded. Case-Laws Income Tax Wed, 25 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787225