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    <title>2026 (5) TMI 1544 - ITAT INDORE</title>
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    <description>Penalty under section 272A(1)(d) was considered unsustainable where the assessees had filed replies and furnished material in response to section 142(1) notices, and the Assessing Officer completed scrutiny assessments under section 143(3) after taking those replies into account. As no best judgment assessment under section 144 was made, the Tribunal treated the notice purpose as fulfilled and found no basis for penalty in the absence of a deliberate or contumacious default. It also noted that identical penalties in group matters had already been deleted on the same reasoning.</description>
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      <description>Penalty under section 272A(1)(d) was considered unsustainable where the assessees had filed replies and furnished material in response to section 142(1) notices, and the Assessing Officer completed scrutiny assessments under section 143(3) after taking those replies into account. As no best judgment assessment under section 144 was made, the Tribunal treated the notice purpose as fulfilled and found no basis for penalty in the absence of a deliberate or contumacious default. It also noted that identical penalties in group matters had already been deleted on the same reasoning.</description>
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