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Does Section 40(a)(ia) cover cases of short deduction of TDS?

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....oes Section 40(a)(ia) cover cases of short deduction of TDS? <br> Query (Issue) Started By: - Ramanathan Seshan Dated:- 21-6-2025 Income Tax <br> Got 1 Replies <br> Income Tax<br> <br> Dear Experts, S....

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....ince the proviso states that disallowance applies where "an assessee fails to deduct the whole or any part of the tax" under Chapter XVII-B, can short deduction be considered a failure to deduct, ther....

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....eby attracting disallowance under this section? Regards, S Ram --Reply By: Padmanathan KV The Reply: It is a debatable issue. Culcutta HIgh Court in 361 ITR 432 and Delhi High Court in 447 ITR 299....

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.... has taken a view that disallowance under section 40(a)(ia) is not attracted on short-deduction. However, Kerala High Court in 380 ITR 284 has taken a view that "tax deductible at source under Chapt....

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....er XVII-B" occurring in the Section 40(a)(ia) has to be understood as tax deductible at source under the appropriate provision of Chapter XVII-B and hence, disallowance is attracted for short-deductio....

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....n also. <br>***<br> Discussion Forum - Knowledge Sharing....