Penalty u/s 271(1)(b) - non-compliance to statutory notices - The order was passed under s. 143(3) and...

Penalty u/s 271(1)(b) - non-compliance to statutory notices - The order was passed under s. 143(3) and not under s. 144 of the Act. This means that subsequent compliance in the assessment proceedings was considered as good compliance and the defaults committed earlier were ignored by the AO. Therefore, in such circumstances, there could have been no reason to come to the conclusion that the default was willful. - AT .....

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