ITAT Kolkata – Penalty u/s 271(1)(b) Deleted; Assessment u/s 143(3) Implies Condonation

Manoj Kumar Patodia Vs DCIT (ITAT Kolkata) ITAT Kolkata – Penalty u/s 271(1)(b) Deleted; Completion of Assessment u/s 143(3) Implies Condonation of Alleged Non-Compliance In Manoj Kumar Patodia (AY 2006-07), penalty of ₹30,000/- u/s 271(1)(b) was levied for alleged non-compliance with notices u/s 143(2) & 142(1) during reassessment proceedings relating to foreign bank account information. The CIT(A) upheld the penalty alleging willful non-cooperation. The ITAT held that since the AO ultimately completed assessment u/s 143(3) and not u/s 144, any alleged non-compliance stood impliedly c...