s. 40(a)(ia) Disallowance has to be made irrespective the fact that whether payment is made during the year or not

In this case ITAT Mumbai  distinguished the Allahabad High Court’s ruling in the case of CIT v. Vector Shipping Services (P) Ltd. (ITA No.122 of 2013) and held that the issue of ‘paid and payable’ was not subject of reference before the Allahabad High Court. The issue therein was decided on basis that tax has already been deducted, hence no disallowance under Section 40(a)(ia) of the Act was made in that case. However, the Calcutta High Court in the case of CIT v. Crescent Export Syndicate [2013] 33 taxmann.com 250 (Cal), and Gujarat High Court in the case of Sikandarkhan N. ...