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    <title>2020 (12) TMI 549 - ITAT MUMBAI</title>
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    <description>Penalty for default in payment of self-assessment tax cannot survive where the assessee&#039;s return disclosed nil income and the quantum addition creating the alleged tax liability was deleted in appeal. Once the deduction claim was allowed in the quantum proceedings, the basis for treating the assessee as being in default under section 221(1) disappeared, because no self-assessment tax was payable on the returned income. The penalty was therefore unsustainable and was deleted.</description>
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      <description>Penalty for default in payment of self-assessment tax cannot survive where the assessee&#039;s return disclosed nil income and the quantum addition creating the alleged tax liability was deleted in appeal. Once the deduction claim was allowed in the quantum proceedings, the basis for treating the assessee as being in default under section 221(1) disappeared, because no self-assessment tax was payable on the returned income. The penalty was therefore unsustainable and was deleted.</description>
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