CLAUSE 21(b)
- Any payment which is chargeable under the head “Salaries”, if it is payable outside India or to a non-resident and if tax has not been paid thereon nor deducted therefrom. The details regarding the date of payment, amount of payment and name and address of the payee are to be provided.
- Any payment to a provident or other fund established for the benefit of employees of the assessee, unless the assessee has made effective arrangements to secure that tax shall be deducted at source from any payments made from the fund which are chargeable to tax under the head “Salaries”
CLAUSE 34(a)
Section wise details of TDS/TCS deducted/collected and paid- In addition to details of TDS/TCS auditor has to disclose amount short deducted, TAN of the Assessee, Amount on which TDS /TCS deducted or collected , amount paid and also details of amount of TDS/TCS not paid by the Assessee .
CLAUSE 34(c)
Auditor has to give details of Interest Payable u/s 201(1A) and 206C(7) – To report detail of Interest payable for delay in payment of TDS/TCS.
Yes, In my opinion details regarding non deduction of TDS can be filled in respective clauses irrespective of the fact that the assessee has no TAN.
Further,Non availability of TAN can be shown in clause 34(a)