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    <title>2025 (3) TMI 2178 - ITAT MUMBAI</title>
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    <description>Form 26A furnished during assessment proceedings established that the payees had filed returns, included the payments in income and paid the tax due. Under the proviso to section 40(a)(ia), read with the first proviso to section 201(1), these conditions treat the payer as having deducted and paid tax. Non-electronic filing of Form 26A in the manner prescribed by Rule 31ACB was treated as a procedural lapse that did not negate substantive compliance. Consequently, the disallowance of expenditure under section 40(a)(ia) was deleted.</description>
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