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The High Court quashed the penalty imposed u/s 270A, holding that the foundation for penalty proceedings was extinguished due to the subsequent rectification order. The initial assessment order failed to grant credit for TDS, prompting the petitioner to file a rectification application u/s 154. Despite delays, the rectification order was eventually passed, merging the original assessment order. Consequently, the demands, penalties, and issues arising from the initial assessment order lost sanctity. The court ruled that no further action could be taken based on the flawed initial assessment after the rectification order addressed the errors, rendering the penalty proceedings inconsequential.
The High Court quashed the penalty imposed u/s 270A, holding that the foundation for penalty proceedings was extinguished due to the subsequent rectification order. The initial assessment order failed to grant credit for TDS, prompting the petitioner to file a rectification application u/s 154. Despite delays, the rectification order was eventually passed, merging the original assessment order. Consequently, the demands, penalties, and issues arising from the initial assessment order lost sanctity. The court ruled that no further action could be taken based on the flawed initial assessment after the rectification order addressed the errors, rendering the penalty proceedings inconsequential.
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