TMI Blog2014 (1) TMI 1732X X X X Extracts X X X X X X X X Extracts X X X X ..... count of disallowance of certain claim, penalty cannot be imposed. The Tribunal also recorded that the question of disallowance under section 40[a](ia) of the Act in respect of transporters had given rise to diversified opinion. CIT [A] has further recorded that the department did not question genuineness of the expenditure but disallowed the same merely on the ground that TDS was not deducted. Su ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... der Section 271 [1](c) of the Incometax Act, 1961 { Act for short}. The respondentassessee, a transporter, had failed to deduct tax at source on certain payments covered under section 194C of the Act. During the assessment proceedings, such payments were disallowed, as explained under section 40[a](ia) of the Act. Simultaneously, penalty proceedings were initiated. The Assessing Officer impose ..... X X X X Extracts X X X X X X X X Extracts X X X X
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