2015 (10) TMI 1591

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....25/- is imposed which has been confirmed by Ld. CIT(A). The assessee is aggrieved, hence, has filed this appeal. 3. It is the case of the Revenue that assessee was under an obligation to deduct tax under section 194C on the payments made by it to two firms namely M/s. Fezisons and M/s. Dwarkesh Enterpirses, which concerns have done printing work for the assessee. The details of these works have been given in the table reproduced in para 5.4 of the order of Ld. CIT(A) and for the sake of brevity the same are not being reproduced. The assessee has made payments to M/s. Fezisons aggregating to a sum of Rs. 3,35,808/- which includes payment made for art work for magazine & quality analysis report; visiting cards, quality analysis report of dia....

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....ecification of the customer by using material purchased from a person other than such customer. Thus, it is the case of Ld. AR that though assessee has accepted the addition, that fact ALONE cannot be utilized for confirming the concealment penalty as primarily the obligation of the assessee for deduction of tax does not exist. It is also the case of the assessee that, in any case, nondeduction of tax from the payments made to the aforementioned two concerns arises out of bonafide belief of the assessee that assessee is not under an obligation to deduct tax on such payments. It is also the case of the assessee that no material particulars have been concealed or no inaccurate particulars have been submitted so that concealment penalty could ....