Section 221: Understanding Penalties for TDS Defaults and Timing of Deposits in Relation to Assessing Officer Proceedings.

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....TDS default - Considering the penal nature of section 221, it would be in the fitness of things to make a distinction between a case where the TDS is deposited suo-motu before any proceedings are initiated by the Assessing Officer and a case where the deposit of the TDS is made after initiation of proceedings by the Assessing Officer but before levy of penalty. - AT....