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Levy of penalty u/s 271C - assessee failed to pay the deducted tax within the stipulated time - crucial facts were totally ignored by the AO as well as by the CIT(A) - payment of delayed TDS to the Government Treasury was not a negligent act on the part of the assessee but due to unavoidable circumstances. Therefore, Section 271C of the Act is not properly invoked. - AT
Levy of penalty u/s 271C - assessee failed to pay the deducted tax within the stipulated time - crucial facts were totally ignored by the AO as well as by the CIT(A) - payment of delayed TDS to the Government Treasury was not a negligent act on the part of the assessee but due to unavoidable circumstances. Therefore, Section 271C of the Act is not properly invoked. - AT
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