Warehouse Charges paid without TDS deduction disallowable u/s 40(a)(ia)

Vandana Dinehkumar Inani Vs ITO (ITAT Pune) In this case there was an arrangement between the assessee and warehouses, that the assessee will store the grains in the warehouses for which assessee was liable to pay certain charges. These are nothing but rent as defined in section 194I. Therefore, the assessee was liable to deduct tax at source. The assessee failed to deduct the tax at source. Hence as per section 40(a)(ia) the amount needs to be disallowed. The Ld.AR submitted that the actual amount was paid by the purchaser directly to the warehouses. However, this does not change the characte...