Court Reviews Section 40(a)(i) Disallowance Due to Marginal TDS Deposit Delay for Non-Resident Payments; Seeks Contextual Interpretation.

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....Disallowance u/s 40(a)(i) - marginal delay in deposit of TDS - TDS deducted from payment to non-residents - Only marginal delay in deposit of tax deducted at source has attracted hundred percent disallowance of the concerned expenditure which is not in accordance with context of provisions of section 40(a)(i) of the act. - AT....