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    <title>2025 (12) TMI 1045 - GUJARAT HIGH COURT</title>
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    <description>Penalty under s.270A was challenged on the ground that it was imposed for additions relating to delayed deposit of PF/ESI under s.36(1)(va) without affording the assessee an effective opportunity of hearing, despite requests to keep proceedings in abeyance pending the appeal on the quantum additions. The HC held that denial of a fresh opportunity vitiated the penalty order to that extent, warranting interference in writ jurisdiction. The impugned penalty order was quashed and set aside, and the matter was remitted to the authority to pass a fresh order under s.270A limited to the additions covered by the show-cause notice, after granting a fresh hearing, within 12 weeks.</description>
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    <pubDate>Tue, 25 Nov 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 1045 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=783505</link>
      <description>Penalty under s.270A was challenged on the ground that it was imposed for additions relating to delayed deposit of PF/ESI under s.36(1)(va) without affording the assessee an effective opportunity of hearing, despite requests to keep proceedings in abeyance pending the appeal on the quantum additions. The HC held that denial of a fresh opportunity vitiated the penalty order to that extent, warranting interference in writ jurisdiction. The impugned penalty order was quashed and set aside, and the matter was remitted to the authority to pass a fresh order under s.270A limited to the additions covered by the show-cause notice, after granting a fresh hearing, within 12 weeks.</description>
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