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    <title>2026 (5) TMI 545 - ITAT MUMBAI</title>
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    <description>The limitation objection to penalty under section 271(1)(c) failed because, after the quantum appeal reached the Tribunal, the penalty order was tested under the main limb of section 275(1)(a), and no breach of that limitation was shown. The objection that the penalty proceedings were vitiated for want of a valid show-cause notice also failed, as the notices consistently conveyed a concealment charge and the later notice cured any ambiguity in the earlier one. On the merits, the penalty issue was remitted to the first appellate authority for fresh adjudication after giving the assessee a reasonable opportunity.</description>
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      <link>https://www.taxtmi.com/caselaws?id=791343</link>
      <description>The limitation objection to penalty under section 271(1)(c) failed because, after the quantum appeal reached the Tribunal, the penalty order was tested under the main limb of section 275(1)(a), and no breach of that limitation was shown. The objection that the penalty proceedings were vitiated for want of a valid show-cause notice also failed, as the notices consistently conveyed a concealment charge and the later notice cured any ambiguity in the earlier one. On the merits, the penalty issue was remitted to the first appellate authority for fresh adjudication after giving the assessee a reasonable opportunity.</description>
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