Assessee cannot be held liable to deduct TDS merely on the basis of book entry

The dispute is regarding treating the assessee in default u/s 201 (1) and consequential levy of interest u/s 201 (1A) for failure to deduct TDS in respect of amounts payable to M/s Overseas Shipbuilding Cooperation Center in connection with consultancy work. The actual payment of the amount was dependent on certain regulatory compliances and approvals which were ultimately not received. The payment had also not been made. Therefore in such a situation no income on account of such payment could said to have been accrued to the non resident. The assessee had neither made the payment nor had clai...