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    <title>2025 (7) TMI 1022 - ITAT DELHI</title>
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    <description>The ITAT Delhi held that penalty under section 272A(1)(d) for non-compliance of notices during assessment proceedings was not sustainable. The tribunal found that the notices issued to the assessee were unsigned, making them illegal, invalid and inoperative in the eyes of law. Such defective notices cannot vest the issuing authority with jurisdiction to proceed with assessment. The CIT(A) had not disputed the fact that notices lacked digital or manual signatures. The tribunal emphasized that unsigned notices amount to no notice at all, therefore non-compliance cannot be established. The reasoning that the assessee was aware of pending proceedings and suffered no prejudice was held irrelevant and cannot validate an invalid notice. Relying on various HC and ITAT decisions, the tribunal allowed the assessee&#039;s appeal and deleted the penalty.</description>
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    <pubDate>Wed, 09 Apr 2025 00:00:00 +0530</pubDate>
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      <title>2025 (7) TMI 1022 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=774954</link>
      <description>The ITAT Delhi held that penalty under section 272A(1)(d) for non-compliance of notices during assessment proceedings was not sustainable. The tribunal found that the notices issued to the assessee were unsigned, making them illegal, invalid and inoperative in the eyes of law. Such defective notices cannot vest the issuing authority with jurisdiction to proceed with assessment. The CIT(A) had not disputed the fact that notices lacked digital or manual signatures. The tribunal emphasized that unsigned notices amount to no notice at all, therefore non-compliance cannot be established. The reasoning that the assessee was aware of pending proceedings and suffered no prejudice was held irrelevant and cannot validate an invalid notice. Relying on various HC and ITAT decisions, the tribunal allowed the assessee&#039;s appeal and deleted the penalty.</description>
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