Amount paid at any time without deducting tax therefrom would be hit by Sec.40(a)(ia) disallowance

IT : Where assessee challenged disallowance made by Assessing Officer on account of non-deduction of tax at source while making payments to sub-contractors on ground that disallowance under section 40(a)(ia) could only be made in respect of sums remaining outstanding at end of year, following order passed by Gujarat High Court in case of CIT v. Sikandar Khan N. Tanvar [2013] 357 ITR 312/[2014] 220 Taxman 256/[2013] 33 taxmann.com 133 plea raised by assessee was to be rejected