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    <title>2026 (5) TMI 392 - ITAT RAIPUR</title>
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    <description>Where the underlying quantum dispute had been settled under the Vivad Se Vishwas Scheme and the assessee sought withdrawal of the first appeal, the penalty connected with that settled dispute could not be confirmed without first addressing the legal effect of the settlement. The appellate authority&#039;s confirmation of penalties under section 271(1)(b) and section 271(1)(c) was therefore found improper, as the withdrawal request and accepted declaration were material facts. The impugned penalty orders were set aside and the assessee&#039;s appeals were allowed.</description>
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      <title>2026 (5) TMI 392 - ITAT RAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=791190</link>
      <description>Where the underlying quantum dispute had been settled under the Vivad Se Vishwas Scheme and the assessee sought withdrawal of the first appeal, the penalty connected with that settled dispute could not be confirmed without first addressing the legal effect of the settlement. The appellate authority&#039;s confirmation of penalties under section 271(1)(b) and section 271(1)(c) was therefore found improper, as the withdrawal request and accepted declaration were material facts. The impugned penalty orders were set aside and the assessee&#039;s appeals were allowed.</description>
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      <pubDate>Thu, 16 Apr 2026 00:00:00 +0530</pubDate>
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