TDS deductible on Audit Fees provision credited to Auditors Account

Citadel Fine Pharmaceuticals (P.) Ltd. Vs ACIT (ITAT Chennai) On perusal of section 194J of the Act, we find that tax is deductible at source either at the time of credit of expenditure to the account of the payee or at the time of payment whichever is earlier. In the instant case, the assessee had made provision for audit fees to the account of the payee which fact has been mentioned by the ld CITA. Hence the provisions of section 194J of the Act are clearly attracted and non-deduction of tax at source would automatically invite disallowance u/s. 40(a)(ia) of the Act. The statutory auditor is...