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The ITAT reduced the penalty imposed under Section 272B(2) from Rs. 23,20,000 to Rs. 10,000 for the assessee's failure to obtain and report PAN details of 232 customers who purchased jewellery. The Tribunal determined that multiple instances of non-compliance constituted a single default rather than separate offenses, considering this was the first year after the PAN reporting requirement was introduced (effective January 2016). The decision aligned with precedent from the Delhi HC in DHTC Logistic Ltd. and was consistent with the AO's previous treatment of similar defaults by the same assessee. The ITAT noted that the statutory amendment specifying 'ten thousand rupees for each such default' only came into effect from September 2019.