In the present case it has been held that the remittance made by the assessee was against the import of goods and did not attract the provision of withholding tax and therefore the requirement to furnish the details under section 195(6) read with rule 37BB of the Income-tax Rules, 1962 was not mandatory. Further, Form 15CA/15CB was required to be submitted only for those payments which are chargeable to tax in India. The appellate tribunal further observed that there was a conflict between section 195 and rule 37BB regarding the compliance with form 15CA and that the Rules were amended with effect from December 16, 2015 in which the list of payments of specified nature mentioned in rule 37BB, which do not require submission of forms 15CA and 15CB, had been expanded from 28 to 33 of the Act. Hence, there was lack of clarification of words expressively in the provisions and therefore the amendment came into effect from December 16, 2015. In view of the above the penalty provisions under section 271-I of the Act would not be applicable in the case. (AY. 2016-17)