https://www.taxtmi.com/caselaws?id=790723 Where tax has been deducted at source, but under an incorrect provision or at a lower rate, the default is treated as short deduction rather than complete failure to deduct. In that situation, the proper enquiry is under Section 201 of the Income-tax Act, 1961, and disallowance under Section 40(a)(ia) is not attracted. The court applied a strict construction to this deterrent provision and preferred the interpretation favourable to the assessee where conflicting views existed, leaving short deduction to be dealt with under the TDS default framework rather than expense disallowance. en-us Fri, 24 Apr 2026 00:00:00 +0530 Wed, 29 Apr 2026 08:16:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790723 Where tax has been deducted at source, but under an incorrect provision or at a lower rate, the default is treated as short deduction rather than complete failure to deduct. In that situation, the proper enquiry is under Section 201 of the Income-tax Act, 1961, and disallowance under Section 40(a)(ia) is not attracted. The court applied a strict construction to this deterrent provision and preferred the interpretation favourable to the assessee where conflicting views existed, leaving short deduction to be dealt with under the TDS default framework rather than expense disallowance. Case-Laws Income Tax Fri, 24 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790723