Section 40(a)(ia) TDS Requirements Not Met: Assessee Not Liable Due to Indirect Payment by Bank.

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....Disallowance u/s 40(a)(ia) - the TDS provisions will be applicable only when the services are utilized, respective payments made directly to the service provider. In this case, assessee is only the observer and the respective payments were made by the bank and recovered from the assessee. Therefore, provisions of section 40(a)(ia) of the Act is not applicable in the present case. - AT....