Section 263 can be invoked for late deduction and deposit of TDS

Brief of the case: ITAT Kolkatta has held In the case of Menally Sayaji Engineering Ltd. VS -CIT that if assessee  failed to deduct TDS during the previous year on payments of management service fee and royalty debited to the profit and loss account and if in his Assessment Order Passed U/s. 143(3) AO fails to make disallowance for such expenses than such order passed by AO is erroneous and prejudicial to the interest of the revenue and  revision proceedings under section 263 initiated by CIT under section 263 is valid. ITAT Further held that to take benefit of amended Section 40(a)(ia) tax ...