Section 40(a)(ia): TDS Deduction Required for Both Paid and Unpaid Amounts, Dismissing "Payable" vs. "Paid" Argument.

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....Disallowance u/s 40(a)(ia) - Failure to deduct TDS - whether the scope is limited “payable” and not to the amount “already paid” - the expression "payable" is descriptive of the payments which attract the liability for deducting tax at source and it has not been used in the provision in question to specify any particular class of default on the basis as to whether payment has been made or not. The semantical suggestion by the learned counsel for the appellant, that this expression “payable” be read in contradistinction to the expression “paid”, sans merit and could only be rejected. - SC....