If section 40(a)(i) disallowance been made, no liability arise u/s. 201

There is no dispute with reference to the fact that assessee made provision for expenses to an extent of Rs. 10,01,98,459/- on about 23 items in the books of account. There is also no dispute to the fact that entire provision so made was disallowed in the computation under the head ‘tax deductible but not deducted on provisions as on 31st March, 2007′ in the computation of income. Therefore, the entire provision so made was disallowed under section 40(a) (i) / (ia) while filing the return of income by the itself. When the payment/ credit was made to the individual payee identified,...