Delay in TDS deposit (31-214 days) due to COVID-19 held reasonable cause. Sanction order mechanically passed, vitiated.

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....Delay in depositing TDS amount ranging from 31 to 214 days due to COVID-19 pandemic constituted reasonable and sufficient cause. As per High Court [2023 (11) TMI 447], failure to comply with TDS deposit provisions was attributable to reasonable causes arising from COVID-19 pandemic. Sanction order passed without due application of mind and mechanically, blaming petitioners for not filing exemption/relaxation notifications/circulars, vitiated. Cognizance u/ss 279B, 2(35), and 278(B) of IT Act improper as latter two are not penal provisions. Revision allowed, delay condoned. Supreme Court dismissed Special Leave Petition, declining to interfere with High Court order.....