Year-End Provisions Attract TDS – Disallowance u/s 40(a)(ia) Does Not Bar Action u/s 201 – Matter Restored for Limited Verification – ITAT Bangalore

Embassy Property Developments Private Limited Vs CIT (ITAT Bangalore) Year-End Provisions Attract TDS – Disallowance U/s 40(a)(ia) Does Not Bar Action U/s 201 – Matter Restored for Limited Verification – ITAT Bangalore In the case of Embassy Property Developments Pvt. Ltd. for AY 2017-18, the assessee had created year-end provisions of ₹58.06 crore without deducting TDS at the time of making such provisions. However, it suo motu disallowed 30% (₹17.41 crore) u/s 40(a)(ia) and subsequently deducted TDS upon crystallization of liability when invoices were received. The DCIT (TDS) t...