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Non-deduction of TDS u/s 194A: Clarificatory proviso retroactively addresses unintended consequences. Payee included amount in income.

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....Non deduction of TDS u/s 194A - additions u/s 40(a)(ia) - payee has taken the amount in computing its income and paid tax thereon - the proiviso that was inserted w.e.f. 1.4.2013 are to remedy unintended consequences and therefore, the same are treated as clarificatory in nature and retrospective in operation - AT....

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