Disallowance Remanded Because U/s 13A Exemption Not Automatic for TDS

DCIT Vs Vijaya Bank (ITAT Bangalore) 13A Exemption Not Automatic Shield: Test of Section 201 Proviso Key- Vijaya Bank’s 40(a)(ia) Issue Sent Back Reassessment u/s 143(3) r.w.s. 147 resulted in disallowance of Rs.6,98,06,208 u/s 40(a)(ia) on the ground that Assessee failed to deduct TDS u/s 194A on interest paid to a political party (All India Congress Party). CIT(A) deleted the disallowance by relying on Punjab & Haryana High Court ruling in Canara Bank, holding that when payee’s income is exempt u/s 13A, payer cannot be treated as assessee in default u/s 201 & consequently no disa...