No hearing opportunity required if corrigendum issued to levy penalty under different sec. had no major impact

INCOME TAX : Where a corrigendum to order under section 143(3) was issued in terms of which section under which penalty proceedings were initiated was to be read as section 271AAB instead of section 271AAA, since there is no substantial difference between two sections except in respect of applicability which depends upon date when search has been initiated, plea raised by assessee that he should have been given an opportunity of hearing before issue of corrigendum, deserved to be rejected

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