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    <title>2025 (3) TMI 1816 - ITAT DELHI</title>
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    <description>Penalty under section 271(1)(c) could not survive once the quantum assessment was quashed for want of a valid notice under section 143(2). The assessment had been framed with additions under sections 68 and 69C read with section 115BBE, but the Tribunal had already held that the jurisdictional defect in issuing the notice by the proper officer vitiated the assessment. As the foundational assessment ceased to exist, the penalty based on those additions had no independent footing and was deleted.</description>
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      <description>Penalty under section 271(1)(c) could not survive once the quantum assessment was quashed for want of a valid notice under section 143(2). The assessment had been framed with additions under sections 68 and 69C read with section 115BBE, but the Tribunal had already held that the jurisdictional defect in issuing the notice by the proper officer vitiated the assessment. As the foundational assessment ceased to exist, the penalty based on those additions had no independent footing and was deleted.</description>
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