Section 40 (a) (ia) applies even in respect of amount paid & not merely payable to contractors

Section 40 (a) (ia) applies even in respect of amount paid and not merely payable to the contractors and therefore CIT (A) was justified  in confirming dis-allowances under section 40 (a) (ia) as the assessee had failed to deduct tax under section 194C Valibhai Khanbhai Mankad Vs DCIT (ITAT Ahmedabad) Whether CIT(A) has erred in confirming the dis-allowance of Rs. 7,93,34,193/- u/s 40(a)(ia) on the ground that the assessee has filed Form No. 15J with CIT on 26.02.2009 instead of on or before 30th June, 2006 in as much the there is no failure to deduct tax at source under section 194C since t...