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2023 (9) TMI 205 - ITAT PUNEOrder u/s. 201 (1) r.w.s. 201(1A) - Non deduction of TDS - payees concerned have offered the same to tax and therefore, they duly stand assessed - HELD THAT:- We are afraid to accept the assessee’s instant sole substantive contention for want of the corresponding records and evidence emanating from the case files. We make it clear that although the legislature has diluted the provisions of the impugned TDS recovery mechanism u/secs. 201(1) r.w.s. 201(1A) subject to only to the condition that it is incumbent for the “assessee(s) – in-default” to file the relevant details to this effect going by sec. 201(1) first proviso introduced in the Act vide Finance Act, 2012 w.e.f. 01.07.2012. This is indeed coupled with the fact that the learned lower authorities have also rejected the assessee’s contention for the very reason only as it is evident from the NFAC’s above extracted detailed discussion. We thus see no merit in these assessee’s identical sole substantive grievance. The same stands rejected.
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