Tax Deduction Dispute: Non-deduction u/s 195 leads to addition u/s 40(a)(i) for Facebook Ireland Payments.

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....TDS u/s 195 - addition u/s 40(a)(i) - non-deduction of taxes from payment made to Facebook Ireland Limited - Section 40(a)(i) acts as a restriction on the deductibility of expenses under section 30 to 38, and, as a corollary to this legal position, when the related expenditure is not claimed as deduction under section 30 to 38, this disallowance cannot be pressed into service at all. - AT....