Taxpayer Not Liable for TDS Non-Deduction Due to Retrospective Amendment u/s 195(1) of Income Tax Act.

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....TDS u/s 195 - disallowance u/s 40(a)(i) - AO has invoked Explanation-2 to Sec.195(1) as inserted by Finance Act, 2012 w.r.e.f. 01.04.1962. However, the assessee could not be expected to deduct tax at source in this year by foreseeing such a future amendment to law. In the impugned year, there was no such obligation on the assessee to deduct TDS but such obligation has arisen out of subsequent amendment to law which assessee could never anticipate. - AT....