Non-deduction of TDS on lease rent disallowed under IT Act Section 40(a)(ia); conditions unmet per 2012 Finance Act.

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....Disallowance u/s 40(a)(ia) for non deduction of TDS - The receiver of lease rent has filed the returns of income belatedly subsequent to the impugned proceedings - assessee cannot be said to have satisfied the conditions prescribed in the proviso to sec. 201 of the Act inserted by the Finance Act, 2012 - AT....