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I find no merit whatsoever in the challenge before me. As pointed out in counter, the contents of the assessment order and the averments in writ petition are wholly unconnected as the addition made in the impugned order is in terms of the Section 69A & 115B of the Act and not Section 80P. Also and more importantly, the petitioner has not co-operated in the least in the framing of assessments and has ignored all communications and notices issued by the Department. It has not even defrayed its statutory responsibility of filing of a return of income for the period in question.

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Sec. 69, 115BBE & 271AAC(1) of income Tax Act, 1961— Penalty —DEVAPALAYAM PRIMARY vs. ITO.[2020] 21 ITCD Online 31 (MAD)

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