https://www.taxtmi.com/caselaws?id=800013 Tax deducted at source on interest payments prevents expense disallowance for non-deduction, even where the deduction is alleged to be at a lower applicable rate. Section 40(a)(i) addresses failure to deduct tax or failure to deposit tax after deduction; it does not apply solely to a shortfall in the rate deducted. Alleged short deduction is to be addressed through proceedings under section 201 rather than by directing disallowance under section 40(a)(i). Revision under section 263 cannot rest on an assertion that an assessment is erroneous and prejudicial to revenue merely because tax was deducted at a lower rate. en-us Mon, 21 Sep 2026 00:00:00 +0530 Wed, 30 Sep 2026 08:41:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800013 Tax deducted at source on interest payments prevents expense disallowance for non-deduction, even where the deduction is alleged to be at a lower applicable rate. Section 40(a)(i) addresses failure to deduct tax or failure to deposit tax after deduction; it does not apply solely to a shortfall in the rate deducted. Alleged short deduction is to be addressed through proceedings under section 201 rather than by directing disallowance under section 40(a)(i). Revision under section 263 cannot rest on an assertion that an assessment is erroneous and prejudicial to revenue merely because tax was deducted at a lower rate. Case-Laws Income Tax Mon, 21 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800013