Penalty for late filing of ITR couldn't be deleted just because ITR of previous year was filed belatedly

IT: Whether penalty proceeding under section 272A(2(e) is a separate proceeding from assessment of income and, thus, once assessee, liable to file return under section 139(4A), failed to do so within prescribed time period, provisions of section 272A(2)(e) would attract automatically irrespective of income determined in course of assessment

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