In the result, ITA Nos.606 to 610/Coch/2010 are partly allowed and ITA Nos
Bench: Shri Chandra Poojari, Am & Shri George George K, Jm
penalty under section 271 C of the Income Tax Act". 7. Hence, as per the directions of the Hon. High Court, the assessee has to prove before this Hon. Tribunal that (i) The deductees have paid the tax in respect of the payments made to them by the assessee. (ii) Whether the payments in respect to Backhaul charges and Uplink