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of Penalty levied u/s 271(1)(c) - disallowance u/s 40 (a)(ia) only for lack of payment of TDS while the payment was bonafide - Though the failure on the part of the assessee to deduct tax at source which it was obligated to deduct rendered the amount in question liable for disallowance as an expenditure, but, we are unable to concur with the view taken by the lower authorities that a disallowance for such technical and venial infraction of a statutory provision would justify saddling the assessee with penalty under Sec. 271(1)(c) of the Act. - AT
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