Section 195 Tax Withholding Invalid if Primary Tax Liability Nullified; Section 201 Demands Unsustainable.

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....TDS u/s 195 - withholding demands under section 201 - A tax withholding liability, particularly under section 195, is a vicarious liability and its survival entirely depends on survival of the primary tax liability of income, embedded in the related payments, in the hands of the recipient. Once that primary liability stands quashed, as in this case, the very foundation of tax withholding demands under section 195 ceases to hold good in law. - AT....