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Issues: Whether the penalty under section 272A(2)(e) of the Income-tax Act, 1961 was leviable on the assessee for failure to furnish the return.
Analysis: The assessment order had itself determined the assessee's income as nil. On that factual basis, the omission to file the return was held to be supported by reasonable cause, attracting deletion of the penalty.
Conclusion: The penalty under section 272A(2)(e) was deleted and the appeal was allowed in favour of the assessee.