TMI Blog2010 (4) TMI 836X X X X Extracts X X X X X X X X Extracts X X X X ..... iling of requisite Form 52A by due dates. The hyper-technical default confirmed by the CIT (A) for 1830 days has to be confirmed by us because there is no appeal by the side of the assessee against the sustained penalty, nor was any argument put forth by the representative when this appeal was heard. Non-compliance simpliciter with the provisions of the section of the Act would not automatically l ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is accountant, both were under an impression that the Form 52A was to be filed along with the return of income. It was explained that the requisite form was signed in the month of October, 2002 and was sent to his accountant to be filed with the return of income. Two such forms were filed with Additional Commissioner of Income-tax on June 15, 2005, but these did not contain addresses of the payees ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cause for non-filing of requisite Form 52A by due dates. The hyper-technical default confirmed by the learned Commissioner of Income-tax (Appeals) for 1830 days has to be confirmed by us because there is no appeal by the side of the assessee against the sustained penalty, nor was any argument put forth by the representative when this appeal was heard. So, we confirm the impugned finding and do no ..... X X X X Extracts X X X X X X X X Extracts X X X X
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