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    <title>2025 (9) TMI 172 - ITAT PUNE</title>
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    <description>Penalty exposure under section 271(1)(b) arose from failure to comply with notices under section 142(1) and the show-cause notice under section 144. The assessee offered only that the notices were received by an account clerk who did not place them before the officers, and no adjournment request or sufficient cause was shown. That explanation was found inadequate, and the non-compliance was treated as voluntary, so the penalty was upheld.</description>
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      <description>Penalty exposure under section 271(1)(b) arose from failure to comply with notices under section 142(1) and the show-cause notice under section 144. The assessee offered only that the notices were received by an account clerk who did not place them before the officers, and no adjournment request or sufficient cause was shown. That explanation was found inadequate, and the non-compliance was treated as voluntary, so the penalty was upheld.</description>
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