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ITAT dismissed the assessee's appeal against penalty levied u/s 271C for failure to deduct tax at source on LTC/LFC reimbursements paid to employees for foreign travel. The assessee, a leading banking institution, failed to establish reasonable cause u/s 273B for non-deduction of TDS. ITAT rejected the assessee's contention of bonafide belief that tax was not deductible at source, holding that a major corporate entity with adequate intellectual resources cannot claim lack of knowledge as reasonable cause. The Tribunal found no material to interfere with CIT(A)'s order confirming the penalty, emphasizing that failure to exercise due diligence despite availability of informed resources cannot constitute reasonable explanation for TDS non-compliance.
ITAT dismissed the assessee's appeal against penalty levied u/s 271C for failure to deduct tax at source on LTC/LFC reimbursements paid to employees for foreign travel. The assessee, a leading banking institution, failed to establish reasonable cause u/s 273B for non-deduction of TDS. ITAT rejected the assessee's contention of bonafide belief that tax was not deductible at source, holding that a major corporate entity with adequate intellectual resources cannot claim lack of knowledge as reasonable cause. The Tribunal found no material to interfere with CIT(A)'s order confirming the penalty, emphasizing that failure to exercise due diligence despite availability of informed resources cannot constitute reasonable explanation for TDS non-compliance.
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