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2016 (5) TMI 1222 - ITAT BANGALORETDS liability on provisions made as at the end of the accounting year - Held that:- The undisputed fact is that the provisions, made at the end of the accounting year are reversed in the beginning of the next year. No payees are identified. The exact amount of liability also cannot be quantified. The provisions are made merely on for Management Information System. In our considered opinion, liability to deduct tax at source does not arise. Assessee-company is not liable to deduct tax at source as no income has accrued in the hands of the payee. - Decided in favor of assessee
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