Penalty u/s 271-C Not Applicable If High Court Admits Substantial Question of Law on TDS Non-Deduction.

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....Penalty u/s.271-C - non deduction of TDS on Leave Travel Allowance (LTA) - reasonable cause for the failure - when the High Court admits substantial question of law on an addition, it becomes apparent that the addition is certainly debatable. In such circumstances no penalty can be levied u/s 271C. - AT....