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2014 (11) TMI 1086 - GUJARAT HIGH COURT
TDS liability - difference / short deduction of TDS due to application of wrong provision - Held that:- Difference in shortfall was due to the applicability of provisions. The assessee has deducted tax at source u/s. 194C whereas according to the Assessing Officer provisions of section 194I are applicable. No doubt assessee is in default as per provisions of sec. 201 but disallowance of the expenditure is not permissible u/s. 40(a)(ia) - Decided in favour of assessee