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The ITAT held that the errors in the assessee's quarterly TDS returns were typographical and did not demonstrate any willful attempt to evade tax or defraud the revenue. The AO's issuance of a single consolidated penalty order under section 271C for multiple assessment years and quarters was found to be legally impermissible, rendering the order void ab initio. Consequently, the levy of penalty under section 271C was quashed, and the assessee's appeal was allowed.
The ITAT held that the errors in the assessee's quarterly TDS returns were typographical and did not demonstrate any willful attempt to evade tax or defraud the revenue. The AO's issuance of a single consolidated penalty order under section 271C for multiple assessment years and quarters was found to be legally impermissible, rendering the order void ab initio. Consequently, the levy of penalty under section 271C was quashed, and the assessee's appeal was allowed.
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