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2011 (9) TMI 638 - AT - Income TaxPenalty u/s 271C - Non deduction of TDS u/s 194A - The payment was made to the sister concern and the group has about 100 separate concerns at various places and large number of inter group transaction takes place involving large sums - assessee is under an obligation to deduct tax and the person making the deduction of tax at source is required to pay such deducted amount to the credit of the Central Government in the manner prescribed u/s.200 - Supreme Court in the case of Hindustan Coca Cola Beverage (P.) Ltd. v. CIT [2007 -TMI - 1676 - SUPREME COURT OF INDIA] wherein the applicability of ss. 194C, 194I, 201(1A) has been explained, we have no hesitation in setting aside the orders of the authorities below and delete the addition - Decided in favor of the assessee
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