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Sec. 40(a)(ia) of Income Tax Act, 1961—Business Disallowance — Amendment brought to the Section 40(a)(ia) by the Finance Act, 2014 w.e.f. 01.04.2015, it is clear that the intent of legislature to reduce the hardship, it is proposed that in case of non-deduction or non-payment of TDS on payments made to residents as specified in section 40(a)(ia), the disallowance shall be restricted to 30% of the amount of expenditure claimed. - KENDRAPARA CO-OPERATIVE BANK LTD. V/s ASSTT. CIT - [2020] 82 ITR (TRIB) 188 (ITAT-CUTTACK)