Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)
section 195 of IT. Act and DTAA between India and USA, the Assessee company was under bon-fide belief that no tax is deductible and therefore, it had not committed any infringement of law for which penalty u/s 271C is to be levied on account of non- deduction of tax at source on payments to non-resident.” 3. Succinctly