Tribunal supports assessee: No TDS deduction failure due to zero payable amounts; disallowance u/s 40(a)(ia) unwarranted.

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....Disallowance u/s 40(a)(i) as assessee not deducted TDS - The Tribunal agreed with the assessee's argument that there was no failure to deduct TDS, as the amounts payable to financial institutions were nil. - ITAT accepted the justification provided by the assessee concerning the percentage completion method as per Accounting Standard AS-7. - Moreover, it accepted the contention that the interest paid was cumulative and claimed as expenditure upon project completion. As a result, the disallowance under section 40(a)(ia) was deemed unwarranted.....