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Section 40(a)(ia) cannot be seen as intended to be a penal provision to punish the lapses of NON-TDS...

Section 40(a)(ia) cannot be seen as intended to be a penal provision to punish the lapses of NON-TDS when the recipients have taken into account income embedded in the payments, paid due taxes thereon and filed income tax returns in accordance with the law - AT .....

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