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    <title>2026 (4) TMI 265 - ITAT PANAJI</title>
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    <description>Penalty under section 271(1)(c) could not be finally sustained on the existing record because the assessee&#039;s explanations and supporting material had not been independently considered and adequate hearing had not been afforded; the matter was remanded to the Assessing Officer for fresh adjudication with due opportunity to the assessee. Penalty under section 271AAA also failed because assessment year 2011-12 did not satisfy the statutory condition of a &quot;specified previous year&quot;, so the provision was inapplicable and the levy was deleted. The outcome was partly in favour of the assessee.</description>
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      <description>Penalty under section 271(1)(c) could not be finally sustained on the existing record because the assessee&#039;s explanations and supporting material had not been independently considered and adequate hearing had not been afforded; the matter was remanded to the Assessing Officer for fresh adjudication with due opportunity to the assessee. Penalty under section 271AAA also failed because assessment year 2011-12 did not satisfy the statutory condition of a &quot;specified previous year&quot;, so the provision was inapplicable and the levy was deleted. The outcome was partly in favour of the assessee.</description>
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