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    <title>2023 (9) TMI 1021 - ITAT INDORE</title>
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    <description>Penalty under section 271C for failure to deduct tax at source on discount allowed to distributors of prepaid SIM cards and recharge vouchers was held unsustainable because the applicability of section 194H was debatable. Divergent High Court and Tribunal views showed that the assessee&#039;s non-deduction was based on a bona fide legal position, and that controversy constituted reasonable cause within section 273B. On that footing, the penalty was not attracted and was deleted.</description>
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      <description>Penalty under section 271C for failure to deduct tax at source on discount allowed to distributors of prepaid SIM cards and recharge vouchers was held unsustainable because the applicability of section 194H was debatable. Divergent High Court and Tribunal views showed that the assessee&#039;s non-deduction was based on a bona fide legal position, and that controversy constituted reasonable cause within section 273B. On that footing, the penalty was not attracted and was deleted.</description>
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