(1.) MR . P.R. Mullick, Advocate, present for the petitioner.
(2.) MR . H.M. Bhatia, Standing Counsel, present for respondent nos. 2 to 4.
(3.) THE petitioner has challenged the order dated 27th September, 2013 and subsequent recovery proceedings dated 05.02.2014. The petitioner is a banker for Public Sector Company, namely, the Oil and Natural Gas Corporation Ltd. (from herein after referred to as "the ONGC"). On certain deposits made by the ONGC petitioner was liable to deduct tax at source under Section 194 (A) of Income Tax Act and therefore, the petitioner has been taken to be an assessee in default and, thereafter, a penalty proceedings under Section 271 (C) of Income Tax Act has been initiated against the petitioner.