Disallowance u/s 40(a)(ia) for mere deduction of TDS under wrong section

Disallowance u/s 40(a)(ia) shall not be made merely because TDS has been deducted u/s 194C instead of Section 194J The provisions of section 40(a)(ia) of the Act has two limbs one is where, inter alia, assessee has to deduct tax and the second where after deducting tax, inter alia, the assessee has to pay into Government Account. There is nothing in the said section to treat, inter alia, the assessee as defaulter where there is a short fall in deduction. With regard to the short fall, it cannot be  ssumed that there is a default as the deduction is not as required by or under the Act, but the...