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    <title>2026 (3) TMI 1337 - ITAT CHENNAI</title>
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    <description>Delay in filing the first appellate appeal was condoned because the explanation showed the assessee learned of the penalty order later, acted promptly, and the record did not show deliberate default; substantial justice prevailed over technicality. Penalty under section 271B was deleted because the tax audit under section 44AB had been completed within time, the only lapse was delayed uploading of the report due to a bona fide technical glitch, and the report was available before assessment completion. The delay was treated as a procedural default covered by reasonable cause under section 273B, with no prejudice to the Revenue.</description>
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      <description>Delay in filing the first appellate appeal was condoned because the explanation showed the assessee learned of the penalty order later, acted promptly, and the record did not show deliberate default; substantial justice prevailed over technicality. Penalty under section 271B was deleted because the tax audit under section 44AB had been completed within time, the only lapse was delayed uploading of the report due to a bona fide technical glitch, and the report was available before assessment completion. The delay was treated as a procedural default covered by reasonable cause under section 273B, with no prejudice to the Revenue.</description>
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