https://www.taxtmi.com/caselaws?id=408059 Penalty under section 271(1)(c) was not leviable where the underlying disallowance arose from non-deduction of tax at source on payments to non-residents. The dispute turned on the taxability of the payments, the applicability of the relevant DTAA, and whether the services constituted fees for technical services, making it a matter of legal interpretation rather than concealment or furnishing of inaccurate particulars. As the assessee had disclosed the relevant facts and supporting material, and mere non-challenge to the quantum addition did not establish culpable conduct, the addition-based penalty was deleted. en-us Mon, 22 Mar 2021 00:00:00 +0530 Mon, 31 May 2021 08:34:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=408059 Penalty under section 271(1)(c) was not leviable where the underlying disallowance arose from non-deduction of tax at source on payments to non-residents. The dispute turned on the taxability of the payments, the applicability of the relevant DTAA, and whether the services constituted fees for technical services, making it a matter of legal interpretation rather than concealment or furnishing of inaccurate particulars. As the assessee had disclosed the relevant facts and supporting material, and mere non-challenge to the quantum addition did not establish culpable conduct, the addition-based penalty was deleted. Case-Laws Income Tax Mon, 22 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=408059