No section 40(a)(ia) disallowance for shortfall in TDS due to difference of opinion

Shree Sita Edibles Ltd. Vs ITO (ITAT Raipur) ITAT find that the issue involved in the present appeal lies in a narrow compass, i.e., as to whether or not, a short deduction of tax at source by the assessee would call for triggering the provision of Sec. 40(a)(ia) of the Act for disallowing the amount in question on a proportionate basis as had been done by the A.O in the present case before us. In our considered view, short deduction of tax at source by an assessee by wrongly taking recourse to a wrong provision as provided in Chapter XVII-B of the Act and deducting tax at source at a lower ra...