As per sec. 40(a)(ia) Tax is deductible u/s 193,194A,194C,194H&194J, going by rule of strict rule of interpretation , the default with reference to actual "payment" of expenditure would not entail disallowance.
Then question is , if amount is paid & tax is not deducted, then what will be the consequences.
And is'nt the any amount paid was payable at some point of time.