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Penalty u/s 272A(2)(c) - Non-issuance of TDS certificate in time - assessee was under bonafide belief that once the tax has not been deposited to the Government account then no certificate under section 203 could have been issued and such a bonafide belief falls within the ambit of section 273B, which envisages that no penalty is leviable if the assessee has bonafide reasons. - AT