Section 271C penalty not imposable if TDS was not deductible

Satya Developers Pvt. Ltd. Vs JCIT (ITAT Delhi) Assessee has challenged the imposition of penalty under Section 271C of the Income Tax Act for non deduction of tax at source as per provisions of Chapter XVII-B towards amount paid as External Development Charges (EDC) to Directorate of Town and Country Planning, Haryana (Haryana Government) (DGTCP) through banking channel favouring Haryana Urban Development Authority (HUDA). ITAT held that imposition of penalty of Rs.4,56,440/- and Rs.5,34,000/-under Section 271C of the Act for the Assessment Years 2014-15 and 2017-18 respectively, is not justi...