Interest Payment to Tata Motors Finance Ltd. Not Disallowed Due to Non-Deduction of TDS u/s 201(1) and 40(a)(ia.

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....Addition u/s.40(a)(ia) - assessee had paid interest to M/s. Tata Motors Finance Ltd. without deducting tax at source - when the assessee could not be held as an assessee-in-default u/s. 201(1) of the Act, therefore, we concur with the claim of the Ld. AR that as per the "2nd proviso" to Section 40(a)(ia) of the Act, the aforementioned amount could not have been disallowed in the hands of the assessee company. - AT....