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    <title>2026 (5) TMI 1622 - ITAT AHMEDABAD</title>
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    <description>Penalty for non-compliance with assessment notices was found unsustainable where there was no evidence that the notices had been physically served on the assessee. The record showed the assessee was an agriculturist, a non-filer and held an unregistered PAN, and the assessment had been completed ex parte under section 144 read with section 147. In the absence of valid service of notice, the assessee could not be treated as guilty of default under section 271(1)(b). The penalty was therefore deleted.</description>
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      <description>Penalty for non-compliance with assessment notices was found unsustainable where there was no evidence that the notices had been physically served on the assessee. The record showed the assessee was an agriculturist, a non-filer and held an unregistered PAN, and the assessment had been completed ex parte under section 144 read with section 147. In the absence of valid service of notice, the assessee could not be treated as guilty of default under section 271(1)(b). The penalty was therefore deleted.</description>
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