Payer's Failure to Deduct Tax at Source Triggers Liability u/s 201(1) Despite Receiver Paying Tax on Receipts.

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....Additions made u/s 40(a)(ia) - resident-receiver of amounts, paid tax on such receipts; even when the payer has failed to deduct tax at source - Liability of the assessee u/s 201(1) being treated as an assessee in default confirmed - HC....