Bench: Hon'Ble Kul Bharat & Hon'Ble Manish Boradassessment Year 2012-13 Pan : Aabcs3374B
penalty for tax withholding lapse per se is separately providedfor in Section 271 C, and, section 40(a)(ia) does not add to the same. The provisions of Section 40(a) (ia), as they existed prior to insertion of second proviso thereto, went much beyond the obvious intentions of the lawmakers and created undue hardships even in cases in which