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Imposition of penalty u/s 271(1)(b) - non-compliance of the notice issued under Section 142(1) - if the assessee really had no connection with the Swiss Bank accounts, no prejudice would have been caused to her if she had complied with the notice u/s 142(1) of the Act and filled the consent form. Moreover, it cannot be that penalty is upheld with regard to the attorney holder of the Swiss bank account and not with regard to the account holder no.2 (Appellant-assessee) qua the same bank account. - the penalty imposed upon the Appellant cannot be held to be erroneous and unwarranted - HC
Imposition of penalty u/s 271(1)(b) - non-compliance of the notice issued under Section 142(1) - if the assessee really had no connection with the Swiss Bank accounts, no prejudice would have been caused to her if she had complied with the notice u/s 142(1) of the Act and filled the consent form. Moreover, it cannot be that penalty is upheld with regard to the attorney holder of the Swiss bank account and not with regard to the account holder no.2 (Appellant-assessee) qua the same bank account. - the penalty imposed upon the Appellant cannot be held to be erroneous and unwarranted - HC
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