1982 (1) TMI 103

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..... n was due to be filed on or before 30th June, 1976 but that was filed late on 30th June 1977 by the assessee. The ITO first made the assessment u/s 143(1) and no penalty proceedings were then initiated. Thereafter, the ITO reopened the assessment and completed the same u/s 143(3) and then initiated the penalty proceedings for default u/s 271(1) (a). The explanation of the assessee that the return .....

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