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of Penalty u/s 271(1)(c) - disallowance u/s 40(a)(ia) - The only reason for which the expenditure was disallowed is due to non–deduction of tax at source. In other words, it is statutory disallowance. That being the case, the assessee cannot be accused of submitting inaccurate particulars of income or concealing its income - No penalty - AT
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