https://www.guptachandanassociates.com/assessee-cant-be-treated-as-assessee-in-default-for-non-deduction-of-an-amount-which-was-disallowed-u-s-40a-itat/
Assessee can’t be treated as assessee-in-default for non-deduction of an amount which was disallowed u/s 40(a): ITAT