Penalty u/s. 271C not imposable on a non-taxable entity

Yes Bank Ltd. Vs Add. CIT (TDS) (ITAT Dehradun) ITAT Dehradun held that Uttarakhand Environment Protection and Pollution Control Board (UEPPCB) is a corporation which has been constituted under a Central Act, no tax was deductible. Accordingly, penalty u/s 271C of the Income Tax Act cannot be levied on a non-taxable entity. Facts- The TDS officer observed that Uttarakhand Environment Protection and Pollution Control Board (UEPPCB) had maintained fixed deposits with the Appellant and that the Appellant Bank had not deducted tax at source on the payment of interest on the fixed deposits. The TDS...