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    <title>2025 (4) TMI 1798 - ITAT AGRA</title>
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    <description>Penalty under section 271E for alleged contravention of section 269T could not be sustained where it was wholly dependent on a quantum addition that had already been deleted in assessment proceedings and that deletion had been affirmed in connected matters. Once the underlying addition ceased to exist, the foundation for the penalty also disappeared, and the penalty could not survive independently. The Revenue&#039;s attempt to maintain the penalty despite deletion of the quantum addition was rejected, and the deletion of the penalty was upheld.</description>
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      <description>Penalty under section 271E for alleged contravention of section 269T could not be sustained where it was wholly dependent on a quantum addition that had already been deleted in assessment proceedings and that deletion had been affirmed in connected matters. Once the underlying addition ceased to exist, the foundation for the penalty also disappeared, and the penalty could not survive independently. The Revenue&#039;s attempt to maintain the penalty despite deletion of the quantum addition was rejected, and the deletion of the penalty was upheld.</description>
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