Allowing the appeal of the assessee the Tribunal held that there is no specific bar in the law on the Travel ,eligible for exemption under section 10(5) in respect of a sector of overseas travel and in the absence of such a bar , the assessee cannot be faulted for not inferring such a bar . The assessee was bonafide and reasonable cause and the assessee could not be said to have violated the provisions of section 192 of the Act. ( ITA No. 1717/Mum/ 2019 dt 27 -1 -2021 ) (AY. 2012 -13)
State Bank of India v .ACIT ( 2021) 123 taxmann.com 447 ( Mum) (Trib)
S. 192 : Deduction at source – Salary – Leave travel allowance – Failure to deduct at source – Travel to foreign country and as well as to destinations in India in a composite itinerary -Cannot be considered as assessee in default for failure to deduct tax at source [ .S.10(5) ]