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The ITAT set aside the orders of the Assessing Officer and the First Appellate Authority regarding the demand under section 201(1)/201(1A) for non-deduction of TDS on LTC/LFC reimbursements, citing non-compliance with principles of natural justice due to the assessee's non-receipt of hearing notices. The matter was remanded to the AO for fresh adjudication, directing the assessee to file necessary evidence. Regarding the penalty under section 271C, the tribunal also set aside the impugned penalty order for reconsideration, as the assessee's submissions were not previously considered. Both appeals were allowed for statistical purposes, emphasizing the requirement of fair opportunity for the assessee to present its case before finalizing any demand or penalty.
The ITAT set aside the orders of the Assessing Officer and the First Appellate Authority regarding the demand under section 201(1)/201(1A) for non-deduction of TDS on LTC/LFC reimbursements, citing non-compliance with principles of natural justice due to the assessee's non-receipt of hearing notices. The matter was remanded to the AO for fresh adjudication, directing the assessee to file necessary evidence. Regarding the penalty under section 271C, the tribunal also set aside the impugned penalty order for reconsideration, as the assessee's submissions were not previously considered. Both appeals were allowed for statistical purposes, emphasizing the requirement of fair opportunity for the assessee to present its case before finalizing any demand or penalty.
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