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ITAT held that penalty u/s 271(1)(c) was not sustainable where the assessee voluntarily disclosed correct income and paid due tax before receiving notice u/s 148. The tribunal found that tax and interest were deposited on 27-05-2019, predating the notice issued on 03-03-2020. The assessee's arguments were accepted, emphasizing that the income tax payment was made prior to the statutory notice, rendering the penalty inappropriate. Consequently, the grounds of appeal were allowed, effectively quashing the penalty proceedings against the taxpayer.
ITAT held that penalty u/s 271(1)(c) was not sustainable where the assessee voluntarily disclosed correct income and paid due tax before receiving notice u/s 148. The tribunal found that tax and interest were deposited on 27-05-2019, predating the notice issued on 03-03-2020. The assessee's arguments were accepted, emphasizing that the income tax payment was made prior to the statutory notice, rendering the penalty inappropriate. Consequently, the grounds of appeal were allowed, effectively quashing the penalty proceedings against the taxpayer.
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