Assessee Failed to Justify Non-Deduction of Tax on Loan Processing Fees u/s 194A; Lacked Auditor's Certificate.

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....TDS u/s 194A - processing charges (upfront fee) paid for taking loan from bank - Since, the assessee could not justify the payments without deduction of tax with necessary evidence and also fails to obtain the certificate from the Auditor to the effect what was quantified under relevant Form No.3CD, includes processing fees paid to banks of which provisions of Section 194A has no application. - AT....