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    <title>2025 (2) TMI 1725 - ITAT DELHI</title>
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    <description>Penalty under section 271AAB(1A) could not be sustained where the additions forming its foundation were deleted in quantum proceedings and only one issue was restored to the Assessing Officer for fresh consideration. As the jewellery and unexplained investment additions were fully deleted, no completed addition remained for the relevant assessment year to support the levy. The penalty order was therefore set aside because the underlying tax basis for imposition had ceased to exist.</description>
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      <description>Penalty under section 271AAB(1A) could not be sustained where the additions forming its foundation were deleted in quantum proceedings and only one issue was restored to the Assessing Officer for fresh consideration. As the jewellery and unexplained investment additions were fully deleted, no completed addition remained for the relevant assessment year to support the levy. The penalty order was therefore set aside because the underlying tax basis for imposition had ceased to exist.</description>
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