In the result, the appeals filed by the assessee are allowed
Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh
271(1 )(a) cannot be imposed if the deductor complies with the requirement of sub-section (3) of sec 271H. Hence, it can be said that the fee provided under section 234E would take out from the rigors of penalty u section 271H but of course subject to the outer limit of one year as prescribed under sub-section