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    <title>2026 (6) TMI 1126 - ITAT RAIPUR</title>
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    <description>Penalty for non-compliance with notices under section 142(1) was treated as a procedural measure under section 271(1)(b), intended to secure compliance rather than punish every default. The text states that such penalty is ordinarily not warranted unless the assessee acted in deliberate defiance of law, with contumacious, dishonest conduct, or conscious disregard of legal obligation. On the facts described, the explanation that the notices were not effectively received or noticed, together with the absence of deliberate default, was accepted as reasonable cause. The penalty was therefore deleted and the issue was decided in favour of the assessee.</description>
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      <description>Penalty for non-compliance with notices under section 142(1) was treated as a procedural measure under section 271(1)(b), intended to secure compliance rather than punish every default. The text states that such penalty is ordinarily not warranted unless the assessee acted in deliberate defiance of law, with contumacious, dishonest conduct, or conscious disregard of legal obligation. On the facts described, the explanation that the notices were not effectively received or noticed, together with the absence of deliberate default, was accepted as reasonable cause. The penalty was therefore deleted and the issue was decided in favour of the assessee.</description>
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