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2021 (4) TMI 246 - AT - Income TaxPenalty u/s. 272A(2)(K) - non filing of TDS returns within the prescribed time - HELD THAT:- There is no rebuttal from the departmental side to the clinching fact that since the TDS deductees had not furnished or made available their respective PANs to the assessee/deductor, it was prevented by reasons beyond its control from filing the prescribed TDS returns well within the time prescribed. The fact also remains that their lordships have further observed that full waiver of penalty could not be accepted in the given facts and circumstances. We thus respectfully follow their lordships latter observation and restrict the impugned penalties to the extent of ₹ 25,000/- each in the interest of justice. Necessary computation to follow as per law.
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