Penalty Imposed for Willful Short Deduction of TDS on Brand Fee u/s 271C; Revenue Loss Argument Rejected.

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....Penalty u/s 271C - Short deduction of tax at source (TDS) in respect of Brand fee paid - The argument of the assessee that short deduction does not cause loss to the revenue is not a reasonable explanation and it shows the willful default of the assessee for short deduction - AT....