Section 279 TDS Default Prosecution Approval Quashed as Reasons Were Not Recorded

Rahee Infratech Limited Vs Union of India & Ors. (Calcutta High Court) The Calcutta High Court considered a writ petition challenging the validity of a sanction order dated 19.05.2025 issued under Section 279(1) of the Income Tax Act, 1961 for Assessment Year 2022-23, authorizing prosecution for delayed deposit of TDS. The petitioner contended that it had replied to the show cause notice, explaining that the delay of 1 to 446 days occurred due to reasonable cause and that the reply had not been considered before granting sanction. The Department submitted that a criminal complaint had alre...