During TDS survey conducted at office of assessee, District Mining Officer, it was found that assessee had not collected TCS on amount of compounding fees/fines recovered from illegal miners and transporters of minerals. Assessing Officer treated the assessee as ‘assessee-in-default’ and saddled it with an obligation to make good said non-collection of tax at source. Tribunal upheld said order. High Court held that section 206C(1C) specifically obliges the assessee to collect TCS from a leaseholder or license holder, or with whom the assessee had entered into a contract or otherwise transferred any right or interest, either in whole or in part, in any parking lot or toll plaza or mine or quarry. Further, there was no legislative mandate to collect tax at source from a person who was involved in illegal mining or illegal transportation of minerals. Moreover, there was no legislative mandate to collect TCS on compounding fee/fine collected under section 23A of Mines and Minerals (Development and Regulation) Act, 1957 read with Rule 71(5) of Chhattisgarh Minor Mineral Rules, 2015, as royalty did not include compounding fee/fine and, thus, the Tribunal was unjustified in holding that TCS would be chargeable under section 206C(1C) on compounding fee/fine and the order was to be set aside. SLP of revenue was dismissed. (AY. 2018-19)