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    <title>2007 (6) TMI 297 - ITAT DELHI</title>
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    <description>Amounts described as discounting charges were treated as interest arising from short-term loan arrangements, bringing them within the tax deduction obligation for interest payments. The assessee failed to prove reasonable cause under section 273B, as the transaction was found to be camouflaged and the Director had admitted during survey that the payments were in the nature of interest. Bona fide belief or ignorance of law was rejected, non-deduction was not excused by the payees having paid tax, and proof of mens rea was held unnecessary for penalty under section 271C; the penalty was upheld.</description>
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      <title>2007 (6) TMI 297 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=119362</link>
      <description>Amounts described as discounting charges were treated as interest arising from short-term loan arrangements, bringing them within the tax deduction obligation for interest payments. The assessee failed to prove reasonable cause under section 273B, as the transaction was found to be camouflaged and the Director had admitted during survey that the payments were in the nature of interest. Bona fide belief or ignorance of law was rejected, non-deduction was not excused by the payees having paid tax, and proof of mens rea was held unnecessary for penalty under section 271C; the penalty was upheld.</description>
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      <pubDate>Fri, 29 Jun 2007 00:00:00 +0530</pubDate>
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