In absence of any accrual of income TDS is not deductible

Toyota Kirloskar Motor (P) Ltd. Vs ITO (Karnataka High Court)

The Supreme Court in SHOORJI VALLABH DAS supra has held that income tax is a levy on income and the Act takes into account two points of time at which the liability to tax is attracted i.e., accrual of income or its receipt but substance of the matter is the income. It has further been held that if the income does not result at all, there cannot be a levy of tax even though in book keeping entry is made about a hypothetical income which does not materialize. The H

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