TDS on EDC Payments to HUDA not deductible, Section 271C penalty not sustainable

Pivotal Infrastructure Ltd Vs Addl. CIT (ITAT Delhi) No TDS is required to be deducted on EDC payments made to HUDA, as these payments were made on the directions of DTCP which are deposited with the Consolidated Fund of State, which has also been clarified by DTCP vide Memo No. DTCP/ACCFTS/AO(AQ)/CAO/2894/2018 dated 19-06-2018 issued by Directorate of Town & Country Planning, Haryana. As these payments though made to HUDA, but for and on behalf of DTCP which are being further deposited with Consolidated Fund of State. This is the reason HUDA in its financial accounts showing EDC received ...