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    <title>2025 (3) TMI 92 - ITAT AHMEDABAD</title>
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    <description>Penalty under section 271(1)(b) was held unsustainable where the assessee had sought the reasons and connected documents for reopening but they were not furnished despite reminders. The record also showed a rectification application and a request for adjournment in response to the show-cause notice, indicating that the assessee had not ignored the reassessment proceedings. In these circumstances, the alleged default under section 142(1) was not established as wilful or effective non-compliance warranting penalty, and the penalty was cancelled in favour of the assessee.</description>
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