No Penalty u/s 271C for TDS Non-Deduction Due to Unquantifiable Year-End Provision; Reasonable Cause Accepted.

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....Penalty levied u/s. 271C - Non deduction of TDS - the provision created at the end of the accounting year has not been credited to the relevant parties to whom the payments has to be made for the reason that it was unquantifiable. Further, assessee has suo moto disallowed the said sum under section 40(a)(ia) for non-deduction of TDS. - Therefore there is a sufficient and reasonable cause for not deducting TDS on the year-end provision. - No penalty - AT....