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Sec. 40(a)(ia) of the Income-tax Act, 1961 — Business disallowance — High Court while dismissing the tax appeal of the revenue held that ”Tribunal was justified in upholding the decision of CIT(A) which held that AO was wrong in adding back the amount on the ground that the TDS has not been deducted as the payee i.e. the Delhi Transport Corporation had reflected the amount as its tax liability in its returns“. Revenue filed SLP. Leave granted and Tagged with Civil Appeal No. 1248 of 2016. - PR. CIT V/s SHIVAAI INDUSTRIES (P.) LTD. - [2020] 269 TAXMAN 053 (SC)