No TDS Deduction on External Development Charges; Section 271C Penalty Not Applicable for Payments to Government Departments.

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....Penalty proceedings u/s 271C - Failure to deduct TDS u/s 194C - the payment of EDC is not for carrying out any specific work to be done by HUDA for and on behalf of the assessee but rather DTCP which is a Government Department which levies these charges for carrying out external development and engages the services of HUDA for execution of the work. - There was no TDS liability and, therefore, the impugned penalty was not leviable - AT....