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    <description>A declaration under the Kar Vivad Samadhan Scheme, 1998 could not be rejected for a mere technical error in addressing the pending appeal to the wrong appellate authority. The appeal had in fact been filed with the department, and there was no categorical denial of receipt or timely objection that the papers were unacceptable or required refiling before the proper authority. The Court treated the defect as curable and held that the assessee could not be penalised for it. The declaration was therefore required to be processed on merits under the scheme, and the rejection was unsustainable.</description>
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      <description>A declaration under the Kar Vivad Samadhan Scheme, 1998 could not be rejected for a mere technical error in addressing the pending appeal to the wrong appellate authority. The appeal had in fact been filed with the department, and there was no categorical denial of receipt or timely objection that the papers were unacceptable or required refiling before the proper authority. The Court treated the defect as curable and held that the assessee could not be penalised for it. The declaration was therefore required to be processed on merits under the scheme, and the rejection was unsustainable.</description>
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