When penalty under section 271C of IT Act is not leviable on Assessee for failure to deduct tax at source

RELEVANT PARAGRAPHS: 14. The assessee has also taken a plea that the assessee did not deduct the tax at source on the interest liability credited to L T Ltd. as per the legal advice given by M/s. C.C. Chokshi Co. This explanation of the assessee has been rejected by the C1T(A) by saying that this submission of the assessee that no TDS was deducted by the assessee under a legal advice of M/s. C.C. Chokshi Co., lacks merit because this advice is not obtained by the appellant but by L T Ltd., The CIT(A) further observed that since this advice was neither given to L T Finance from whom the assesse...