23 February 2010
My view,Expenses claimed under the head Profits and gains of business or profession only covered under TDS default in respect of Sec.40(a)(ia)
24 February 2010
The question of disallowance under section 40(a)(ia) arises only when the expenditure is considered by the assessee in calculating the income under the head PGBP. In other words if the expenses are not debited in the p & l A/c, disallowance u/s 40 (a) (ia) does not arise. Consequently prepaid/capital expenditure are outside the purview of the said section.