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2015 (2) TMI 246 - AT - Income TaxDisallowance under section 40(a)(ia) and u/s 40(a)(iii) - Held that:- Only disallowance can be made out of the amounts claimed in the P & L account. Coming to the issue of quantum for disallowance as rightly admitted by Ld. Counsel, the amounts added to the work in progress in earlier year without TDS were also part of the project expenses debited to P & L account during the year. Therefore, whatever is the amount included in the total project cost without making TDS up to the end of the year should be considered for disallowance proportionately at 2.16%. Total amount that should be considered for proportionate disallowance under section 40(a)(ia), being the amount included in the project cost was submitted by assessee as extracted above. AO directed to examine the same and then disallow the proportionate 2.16% under section 40(a)(ia) as in earlier year as per directions of ITAT on this issue. Decided partly in favour of assessee for statistical purposes.
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