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of <h1>No penalty when reasonable cause for failure is shown and taxpayer must get reasonable opportunity to be heard</h1> If an assessee shows to the satisfaction of the assessing officer that a failure triggering penalties arose from reasonable cause, no penalty may be imposed for that failure. Additionally, no penalty order under this chapter can be made without first giving the assessee a reasonable opportunity to be heard. These rules carve out a defense to liability where reasonable cause exists and mandate procedural fairness before imposing penalties.
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