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Penalty u/s 271(1)(b) - assessee has made no response to the questionnaire - there was no wisdom in the assessment order in respect of alleged non-compliance - when the AO has framed the assessment order u/s 143(3) r.w.s. 153A of the Act and assessment order has not been passed u/s 144 of the Act, therefore the penalty u/s 271(1)(b) of the Act, for non-compliance should not be levied. - AT