https://www.taxtmi.com/highlights?id=77392 Penalty u/s 271C - failure to deduct TDS u/s 194C on External Development Charges - The High court noted that the applicability of Section 194C had been explicitly raised in counter-affidavits, providing sufficient notice to the petitioners. Therefore, the court declined to interfere with the show-cause notices at this stage. - Regarding the treatment of the petitioners as an assessee-in-default and the imposition of penalties u/s 221 and 271C of the Act, the court observed that such penalties were not inevitable consequences of default. - In this case, the court found that there was a genuine and bona fide legal issue surrounding the applicability of Section 194C to the supplementary commission. Therefore, the court quashed the penalty proceedings under Section 271C. en-us Mon, 13 May 2024 17:03:31 +0530 Mon, 13 May 2024 17:03:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=77392 Penalty u/s 271C - failure to deduct TDS u/s 194C on External Development Charges - The High court noted that the applicability of Section 194C had been explicitly raised in counter-affidavits, providing sufficient notice to the petitioners. Therefore, the court declined to interfere with the show-cause notices at this stage. - Regarding the treatment of the petitioners as an assessee-in-default and the imposition of penalties u/s 221 and 271C of the Act, the court observed that such penalties were not inevitable consequences of default. - In this case, the court found that there was a genuine and bona fide legal issue surrounding the applicability of Section 194C to the supplementary commission. Therefore, the court quashed the penalty proceedings under Section 271C. Highlights Income Tax Mon, 13 May 2024 17:03:31 +0530 https://www.taxtmi.com/highlights?id=77392