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    <title>2022 (9) TMI 86 - ITAT DELHI</title>
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    <description>Reassessment based on a recorded belief that no return had been filed was invalid where the record showed an e-filed return under a different PAN; the reopening failed for want of proper verification and non-application of mind, so the reassessment was quashed in favour of the assessee. Penalty under section 271(1)(c) could not survive once the quantum assessment forming its sole foundation was set aside; the penalty was therefore deleted. The additions and related penalty liability were removed in full.</description>
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