Court Remands Case for Further Review on TDS Default u/s 194A; Emphasizes Liberal Application of Section 201(1) Proviso.

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....TDS u/s 194A - assessee in default for non-deduction of TDS - Onus upon the assessee to furnish the CA certificates that the payee has paid necessary taxes on income credited by the assessee. However in the case on hand the assessee has submitted PAN of the payee and claimed that the payee has filed income tax return for the year dated 13-07-2009 - None of the authorities below verified the genuineness of the claim of the assessee. We are of the view that the proviso to section 201(1) in beneficial in nature hence the same should be applied in liberal manner - Matter restored back - AT....