Assessee Defaulted on TDS Deduction Liable for Interest u/s 201(1) Regardless of Payee's Tax Status.

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....Default in payment of TDS - liability to pay interest - when the assessee is considered as in-default u/s. 201(1) - precondition - The obligation to deduct and deposit tax at source is thus with reference to tax deductible, i.e., that liable to be deducted under the provisions of Chapter-XVII of the Act, which provides for a mechanism for a lower (including nil) deduction of tax at source u/s. 197. The fact of the payee company having incurred a loss, so that it was not liable to any tax for the relevant year/s, becomes, therefore, largely irrelevant as far as assessee-payer is concerned. - AT....