Year-End Provisions Reversed Next Year Not Liable for TDS Deduction; No Debt Acknowledged, No Disallowance Needed.

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....Disallowance of the year end provision - non deduction of TDS - mere passing of the book entries, which are reversed on the 1st day of the subsequent year, would not give rise to an obligation to deduct TDS, as clearly, there is no debt that can be said to be acknowledged by the Assessee - no such disallowance can be made....