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    <title>2025 (2) TMI 1679 - ITAT MUMBAI</title>
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    <description>The amended proviso to section 40(a)(ia), which permits deduction where tax deducted at source is deposited before the due date under section 139(1), was treated as a curative and beneficial amendment with retrospective effect from the date of insertion. Applying that principle, the disallowance of labour charges could not stand because the deducted tax had been deposited within the return-filing due date. The statutory condition for disallowance was therefore not attracted, and the assessee was entitled to relief.</description>
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      <description>The amended proviso to section 40(a)(ia), which permits deduction where tax deducted at source is deposited before the due date under section 139(1), was treated as a curative and beneficial amendment with retrospective effect from the date of insertion. Applying that principle, the disallowance of labour charges could not stand because the deducted tax had been deposited within the return-filing due date. The statutory condition for disallowance was therefore not attracted, and the assessee was entitled to relief.</description>
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