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    <title>2026 (7) TMI 968 - MADRAS HIGH COURT</title>
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    <description>Recovery of penalty for belated deduction and remittance of tax deducted at source may be stayed pending appeal where a prima facie case exists that Section 271C does not apply. The notes state that CBDT instructions and office memoranda are guidelines and do not create a statutory restriction on discretion to grant stay under Section 220(6). Recovery was stayed pending disposal of the appeals and for two further weeks, subject to the prescribed aggregate payment, while the appeals were to be considered expeditiously. No final determination was made on Section 271C&#039;s applicability.</description>
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    <pubDate>Mon, 06 Jul 2026 00:00:00 +0530</pubDate>
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      <description>Recovery of penalty for belated deduction and remittance of tax deducted at source may be stayed pending appeal where a prima facie case exists that Section 271C does not apply. The notes state that CBDT instructions and office memoranda are guidelines and do not create a statutory restriction on discretion to grant stay under Section 220(6). Recovery was stayed pending disposal of the appeals and for two further weeks, subject to the prescribed aggregate payment, while the appeals were to be considered expeditiously. No final determination was made on Section 271C&#039;s applicability.</description>
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