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    <title>2019 (12) TMI 1209 - ITAT DELHI</title>
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    <description>The Tribunal allowed the assessee&#039;s appeals, obliterating the penalty imposed by the Assessing Officer. The penalty under Section 271(1)(c) was upheld based on seized material and the retrospective applicability of Explanation 5A. However, the penalty order was deemed invalid due to procedural lapses in the notice issued. The additional grounds related to Section 271AAA were not admitted as they were not applicable to the assessment years in question.</description>
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      <description>The Tribunal allowed the assessee&#039;s appeals, obliterating the penalty imposed by the Assessing Officer. The penalty under Section 271(1)(c) was upheld based on seized material and the retrospective applicability of Explanation 5A. However, the penalty order was deemed invalid due to procedural lapses in the notice issued. The additional grounds related to Section 271AAA were not admitted as they were not applicable to the assessment years in question.</description>
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