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Case lawHigh Court › CIT (TDS) v Superintendent of Police
High CourtHelps taxpayerValidity unconfirmeds.272Bs.139As.273Bs.200s.260A

CIT (TDS) v Superintendent of Police

CPC has raised a s.272B penalty of ten thousand rupees for each of 196 deductees whose PANs were invalid in my TDS statement. The deductees gave me those numbers. Is that reasonable cause?

CPC has raised a s.272B penalty of ten thousand rupees for each of 196 deductees whose PANs were invalid in my TDS statement. The deductees gave me those numbers. Is that reasonable cause?

Yes, on these facts. The Punjab and Haryana High Court dismissed the Revenue's appeal against the deletion of a Rs 19,60,000 penalty levied at Rs 10,000 per default for 196 invalid PANs in a quarterly TDS statement. The Court held that whether sufficient cause had been shown within s.273B was a question of fact, on which the CIT(A) and the Tribunal had concurrently found in the assessee's favour after examining the explanation, and that no substance remained in the Revenue's argument.

Decided by the High Court (Ajay Kumar Mittal J and Gurmeet Singh Sandhawalia J) on 2012-08-07, reported as ITA No. 124 of 2012 (Punjab and Haryana High Court), arising from ITA No. 942/CHD/2011 (ITAT Chandigarh Bench 'B'), assessment year 2009-10. It bears on section 272B, section 139A, section 273B, section 200, section 260A of the Income Tax Act 1961, in Penalty, TDS Defaults and Appeals matters.

Validity check could not be completed. Validity check could not be completed. No decision doubting or dissenting from this judgment was located, but no citing-decisions search was run, the session's search budget having been exhausted on primary retrieval. Two limitations on its reach should be stated. First, the judgment turns on concurrent findings of fact under section 273B and does not lay down that an invalid PAN in a TDS statement can never attract section 272B. Second, it was decided on 7 August 2012 and therefore on the pre-2019 text of section 272B, which had three sub-sections and did not contain the words 'for each such default' in sub-section (2) or the sub-sections (2A) and (2B) inserted by Act No. 23 of 2019 with effect from 1 September 2019; the reasonable-cause holding is unaffected by that change but the quantum framework has moved.

Why it matters

This is the answer to the highest-volume s.272B penalty there is, and its shape matters. The deductor did not fail to deduct or to deposit; tax was deducted correctly and paid into the treasury on time. The only default was that the numbers his own deductees had given him turned out to be invalid, and he corrected them as soon as the officer pointed it out, filing revised PANs and a revised statement. Those three facts — correct deduction, correct deposit, prompt correction on notice — are what the Tribunal treated as reasonable cause, and they are what to plead. Two further points give the case reach. First, the Tribunal's reasoning, quoted in the judgment, draws on the co-ordinate decision in Financial Cooperative Bank Limited that 'an obligation to quote PAN/GIR number or to file Form No.60 is that of customer and not that of the bank' — that is the general proposition that the primary duty under rule 114B lies on the person entering the transaction, and it transfers directly to an inoperative-PAN or invalid-PAN argument today. Second, by holding that reasonable cause is a question of FACT, the High Court made concurrent findings below very hard for the Revenue to disturb; a deductor who builds the record before the CIT(A) is building the thing the High Court will not go behind. The limit is the mirror image: a deductor who does not build that record cannot expect the High Court to make the finding for him.

Binding within that High Court's jurisdiction. Persuasive elsewhere.

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