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Appeals against cancellation of penalties under s. 271(1)(a) and s. 273(b) for various assessment years. Analysis: The appeals involved five cases where the Revenue challenged the cancellation of penalties by the CIT (A) for late filing of returns and non-filing of advance tax estimates. The assessee, an individual, faced penalties for delays in filing returns and not submitting advance tax estimates for multiple assessment years. The ITO imposed penalties, but the CIT (A) canceled them after considering extraordinary circumstances, including raids on the assessee's premises, family deaths, and a serious injury due to an attack. The IAC had already waived interest for the delays. The Revenue contended that the penalties were distinct from interest and should not have been canceled solely based on interest waiver. The Revenue argued that penalties should stand despite interest waivers, citing a High Court ruling. However, the assessee's counsel emphasized the exceptional circumstances leading to the delays and justified the CIT (A)'s decision to cancel the penalties. The IAC's satisfaction with the reasons for the delays implied no penalty should be imposed. The CIT (A) found the penalties unjustified given the circumstances. The Tribunal noted that penalties are imposed only for defaults without reasonable cause. Considering the IAC's satisfaction with the exceptional circumstances and the quasi-criminal nature of penalty proceedings, the Tribunal found no justification for penalties. The Tribunal highlighted the need for discretion in penalty imposition, as per Supreme Court precedent. The Tribunal concluded that the penalties were rightly canceled by the CIT (A) based on the extraordinary circumstances and lack of deliberate non-compliance by the assessee. In conclusion, the Tribunal dismissed the Revenue's appeals, upholding the CIT (A)'s decision to cancel the penalties.
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