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ITAT Kolkata – Penalty u/s 271(1)(b) Deleted; Assessment u/s 143(3) Implies Condonation
Case Law Details
- Case Name
- Manoj Kumar Patodia Vs DCIT (ITAT Kolkata)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2006-07
- Courts
- All ITAT, ITAT Kolkata
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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 ...





