Section 40(a)(ia) isn't punitive for non-deduction of TDS if recipients reported income and paid taxes.

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Full Text of the Document

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....Section 40(a)(ia) cannot be seen as intended to be a penal provision to punish the lapses of non-deduction of TDS particularly when the recipients have taken into account income embedded in these payments, paid due taxes thereon and filed ITR in accordance with the law. - AT....