Assessment Order u/s 263 Not Erroneous; No Revenue Loss from Non-Deduction of TDS as per Section 40(a)(ia).

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....Revision u/s 263 - non deduction of tds - the assessment order passed by the A.O. is not erroneous, in so far as it is prejudicial to the interest of the revenue, as there is no loss of revenue on account of non compliance with TDS provisions as the expenditure is not disallowable u/s 40(a)(ia) - AT....