https://www.taxtmi.com/caselaws?id=283656 Penalty under section 271C was held unsustainable where the Tribunal found that the assessee held a bona fide belief that retention or continuation pay paid in Japan was not taxable in India, and that this belief constituted reasonable cause under section 273B. The High Court treated the existence of reasonable cause for non-deduction of tax at source as a primarily factual , and held that such a finding does not ordinarily raise a substantial question of law unless perverse. As the factual finding on bona fides was supported, the Revenue's appeal failed and the penalty was not leviable. en-us Wed, 27 Apr 2005 00:00:00 +0530 Fri, 04 Oct 2019 18:29:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=283656 Penalty under section 271C was held unsustainable where the Tribunal found that the assessee held a bona fide belief that retention or continuation pay paid in Japan was not taxable in India, and that this belief constituted reasonable cause under section 273B. The High Court treated the existence of reasonable cause for non-deduction of tax at source as a primarily factual , and held that such a finding does not ordinarily raise a substantial question of law unless perverse. As the factual finding on bona fides was supported, the Revenue's appeal failed and the penalty was not leviable. Case-Laws Income Tax Wed, 27 Apr 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=283656