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    <title>2026 (2) TMI 1373 - ITAT DELHI</title>
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    <description>Year-end provisions for which payees were not identifiable did not create a tax deduction obligation merely because the assessee voluntarily disallowed the expenditure under Section 40(a)(ia). Tax was deducted and remitted in the following year when bills were received. Applying the principle that no TDS obligation arises where the payee is unidentifiable, the assessee could not be treated as in default under Section 201(1), and consequential interest under Section 201(1A) was not sustainable. The appeal was allowed in favour of the assessee.</description>
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      <title>2026 (2) TMI 1373 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=787225</link>
      <description>Year-end provisions for which payees were not identifiable did not create a tax deduction obligation merely because the assessee voluntarily disallowed the expenditure under Section 40(a)(ia). Tax was deducted and remitted in the following year when bills were received. Applying the principle that no TDS obligation arises where the payee is unidentifiable, the assessee could not be treated as in default under Section 201(1), and consequential interest under Section 201(1A) was not sustainable. The appeal was allowed in favour of the assessee.</description>
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      <pubDate>Wed, 25 Feb 2026 00:00:00 +0530</pubDate>
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