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    <title>2026 (6) TMI 127 - ITAT INDORE</title>
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    <description>Penalty under section 272A(1)(d) was found unsustainable because the assessments were completed under section 143(3) after the assessees participated in the scrutiny proceedings and their replies were considered. No best judgment assessment under section 144 was made, and the notices were treated as having served their purpose. On identical facts, penalties in related group cases had already been deleted at first appellate stage. In the absence of proof of wilful default or contumacious conduct, a mechanical penalty could not be sustained, and the penalty was directed to be deleted.</description>
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