TMI Blog2007 (7) TMI 663X X X X Extracts X X X X X X X X Extracts X X X X ..... ala v. CIT [1971] 82 ITR 570 (SC) where it has been observed that provisions of a section of the Income Tax Act should not be interpreted in such a manner that to make it capable of being an instrument of oppression. 2. The Revenue is aggrieved by an order dated 20th October, 2006 passed by the Income Tax Appellate Tribunal, Delhi Bench 'D in ITA Nos. 4732 4735/Del/2004 relevant for the fi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in respect of the fixture and furniture charges . There is no dispute about the fact that the assessee did deduct tax at source under section 194C of the Act in respect of these charges. On this basis, both the Commissioner as well as the Tribunal came to the conclusion that the Assessee had shown reasonable cause as required by section 273B of the Act and, therefore, the penalty provision unde ..... X X X X Extracts X X X X X X X X Extracts X X X X
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