Penalty Avoided Due to Reasonable Cause for Not Deducting TDS; Income Added u/s 40(a)(i) Ensures Tax Neutrality.

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....Penalty u/s 271C - Reasonable cause - In the substance of this case after the decision of ITAT, the disallowance was sustained but at the same time the assessee was allowed deduction of that income and therefore, the effect was tax neutral. Therefore, the reasonable cause for the assessee not to deduct the TDS which although was added in the income of the assessee u/s 40(a)(i) - Since the effect was revenue neutral assessee has not disputed the levy or addition further in the Hon’ble High Court. - Reasonable cause established - No penalty - AT....