Allowing the appeal, that the issue of applicability of section 194H in respect of the transactions in question was highly debatable and was pending adjudication before the Supreme Court in special leave petitions. It was undisputed that there were two possible views, and the assessee was of the opinion that it was not under obligation to deduct tax at source in terms of Chapter XVII, particularly under section 194H . The assessee’s belief being one of the possible views, failure to deduct the tax at source in respect of the commission or discount allowed to the distributors in light of divergent decisions clearly established the assessee’s view to be a genuine and bona fide. Hence, there was reasonable cause as provided under section 273B to not deduct tax on these transactions. The assessee’s case involving quantum proceeding holding the assessee to be one in default for non-deduction of tax at source under section 194H and consequent liability to pay the tax under section 201 and 201(1A) was pending adjudication before the Supreme Court. The nature of the issue itself highlighted the genuine and bona fide belief of the assessee for not deducting tax at source. Therefore, the penalty levied by the Assessing Officer under section 271C was not justified and liable to be deleted.(AY. 2008-09, 2011-12 to 2014-15)