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    <title>2025 (5) TMI 1589 - RAJASTHAN HIGH COURT</title>
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    <description>Delayed deposit of tax deducted at source, followed by voluntary payment of the tax with interest before issuance of the show-cause notice, was treated as insufficient to justify prosecution sanction under the Income-tax Act. The explanation for the delay was neither doubted nor rejected, and the matter did not involve a complete failure to deduct or deposit tax. In the absence of malicious or contumacious conduct, mere delayed compliance was held not enough to sustain penal prosecution, and the impugned sanction order was set aside.</description>
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      <description>Delayed deposit of tax deducted at source, followed by voluntary payment of the tax with interest before issuance of the show-cause notice, was treated as insufficient to justify prosecution sanction under the Income-tax Act. The explanation for the delay was neither doubted nor rejected, and the matter did not involve a complete failure to deduct or deposit tax. In the absence of malicious or contumacious conduct, mere delayed compliance was held not enough to sustain penal prosecution, and the impugned sanction order was set aside.</description>
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