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HC upheld ITAT's ruling against penalty under s.271C, accepting assessee's reasonable cause defense for TDS non-deduction. Assessee's reliance on legal opinions from Singhania & Co. and Lovelock & Lewis demonstrated bona fide belief. Court considered significant that assessee had sought advance ruling, which remained unprocessed due to Authority Chairman's personal reasons. HC found no mala fide intent, noting assessee derived no benefit from non-deduction. Multiple factors constituted reasonable cause under law, validating non-imposition of penalty. Assessee's explanation sufficiently established absence of willful default, justifying relief from punitive measures.
HC upheld ITAT's ruling against penalty under s.271C, accepting assessee's reasonable cause defense for TDS non-deduction. Assessee's reliance on legal opinions from Singhania & Co. and Lovelock & Lewis demonstrated bona fide belief. Court considered significant that assessee had sought advance ruling, which remained unprocessed due to Authority Chairman's personal reasons. HC found no mala fide intent, noting assessee derived no benefit from non-deduction. Multiple factors constituted reasonable cause under law, validating non-imposition of penalty. Assessee's explanation sufficiently established absence of willful default, justifying relief from punitive measures.
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