"Payable" in TDS Context Includes "Paid" Amounts; Liability to Pay is Key, Ensuring Section 40(a)(ia) Effectiveness.

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....TDS - a harmonious construction of the word 'payable' leads to inevitable conclusion that the said word also includes the 'paid' amount. It is evident that the emphasis is on liability to pay and not on actual payment. If we accept the contention of assessee, then Section 40(a)(ia) would become otiose and the section will not be attracted where payment is made though without deducting tax at source. - HC....