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2005 (7) TMI 63 - HC - Income TaxThe only question that fell for consideration before Tribunal was whether there was reasonable cause for not deducting tax at source u/s 192 in respect of the retention money paid outside the country to the Japanese expatriates working in India. The Tribunal upon consideration of the circumstances recorded a finding of fact that there was reasonable cause for not making the deduction and, accordingly, cancelled the penalty levied upon the assessee u/s 271C - Tribunal found that “As from the facts and from the correspondence exchanged between the assessee and the other authorities, it is clear that the assessee tried to solve the dispute amicably, therefore, it cannot be said that there was any mala fide intention on the part of the assessee” - No question of law much less a substantial question of law therefore arises for our consideration to warrant admission of these appeals
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