In the result, the appeal stands allowed to the extent indicated in the order
Bench: Hon’Ble Shri Vikas Awasthy, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am
271(1)(a) cannot be imposed if the deductor complies with the requirement of sub-section (3) of Section 271H. Hence, it can be said that the fee provided under Section 234E would take out from the rigors of penalty under Section 271H but of course subject to the outer limit of one year as prescribed under ITA No.5140-43/Mum/2018 Lawmen