TDS obligation arises while making provision at
the time of quarterly closure and not when actual exp. is booked
IT:
Statutory provisions of withholding tax clearly envisage deduction of tax at
source de hors
charge under section 4(1), hence assessee would be liable to
deduct tax on provision for expenses created in books of account
IBM
India (P.) Ltd. v. Income-tax Officer (TDS) LTU, Bangalore*