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2001 (11) TMI 6 - SC - Income TaxTDS - refund- allegation that the DDA failed to deduct income-tax at source on the payment of interest made to the buyers as provided under section 194A - It is not correct to contend that unless there are actual assessment proceedings pertaining to any person, he cannot be considered to be an assessee - order of refund was passed in appellate proceedings under the Act attracting s. 240 - HC was right in applying s. 244(1A) for determining interest
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