Revenue Authorities Must Prove TDS Default u/ss 201(1) and 201(1A) Before Enforcing Vicarious Recovery Liability.

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....Demand u/s 201(1) and 201(1A)- TDS default - Onus is on the revenue to demonstrate that the taxes have not been recovered from the person who had the primarily liability to pay tax, and it is only when the primary liability is not discharged that vicarious recovery liability can be invoked. - AT....