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Corporate TaxArticle·24 April 2026

Penalty Reduced

By J the App

Executive Summary

Even where non-compliance with statutory notices is established, penalty under Section 271(1)(b) may be moderated in light of overall circumstances, including evidentiary ambiguities and mutual agreement between parties. 

The Tribunal emphasized finality and proportionality over rigid enforcement in low-stakes disputes.

Issues for Determination

The Tribunal examined whether penalty for non-compliance with notices under Section 142(1) was just...

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