Penalty u/s 271(1)(b) - non-compliance of notice issued u/s...

Penalty u/s 271(1)(b) - non-compliance of notice issued u/s 142(1) - Referring to the precedent set by the Supreme Court in Hindustan Steel Ltd. vs. State of Orissa, the Tribunal emphasized that penalties should not be levied if the conduct of the assessee is not contumacious. In this case, the Tribunal found no evidence of contumacious behavior on the part of the appellant.