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    <title>2023 (2) TMI 168 - ITAT DELHI</title>
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    <description>External development charges paid through HUDA were treated as payment to the State Government through its executing agency, so section 194C was held inapplicable to those payments. As the alleged non-deduction of tax at source could not be founded on section 194C, the basis for penalty under section 271C also failed. The penalty was therefore not sustainable and was directed to be deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=433653</link>
      <description>External development charges paid through HUDA were treated as payment to the State Government through its executing agency, so section 194C was held inapplicable to those payments. As the alleged non-deduction of tax at source could not be founded on section 194C, the basis for penalty under section 271C also failed. The penalty was therefore not sustainable and was directed to be deleted.</description>
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