Section 40(a)(ia) applies only to those amounts ‘payable’ and not to those amounts ‘paid’

Before us, the sole argument of the Revenue is that ‘paid’ and ‘payable’ distinction drawn by the CIT(A) whilst issuing aforesaid  directions to the Assessing Officer on the basis of Special Bench decision (supra) is no longer sustainable in view of the decision of the Hon’ble Calcutta High Court in the case of CI

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