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    <title>2025 (2) TMI 1700 - ITAT DELHI</title>
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    <description>Penalty proceedings under the Income-tax Act could not stand where the underlying assessments had already been quashed for want of valid approval under section 153D. The Tribunal had held that the approval was mechanical, generic, and issued without application of mind, rendering the assessment orders invalid and non est. Because the penalties were wholly consequential to those assessments and based on enhanced income for multiple years, the disappearance of the assessment basis meant the penalty basis also fell away. The penalty was therefore deleted.</description>
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      <description>Penalty proceedings under the Income-tax Act could not stand where the underlying assessments had already been quashed for want of valid approval under section 153D. The Tribunal had held that the approval was mechanical, generic, and issued without application of mind, rendering the assessment orders invalid and non est. Because the penalties were wholly consequential to those assessments and based on enhanced income for multiple years, the disappearance of the assessment basis meant the penalty basis also fell away. The penalty was therefore deleted.</description>
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