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    <title>2013 (11) TMI 320 - ITAT MUMBAI</title>
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    <description>Penalty under section 271(1)(c) was sustained where an assessee, after cancellation of its banking licence, still claimed deduction under section 80P(2)(a)(i) on receipts said to be banking income. The Tribunal treated the claim as made in conscious disregard of the legal position because the assessee knew it could no longer carry on banking business and its auditors had recorded that the banking regime was no longer applicable. Section 176(3A) was held inapplicable because there was no discontinuance of business in the statutory sense. Full disclosure of the claim in the return did not establish a bona fide explanation, and the explanation remained unsubstantiated.</description>
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    <pubDate>Wed, 18 Sep 2013 00:00:00 +0530</pubDate>
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      <title>2013 (11) TMI 320 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=239143</link>
      <description>Penalty under section 271(1)(c) was sustained where an assessee, after cancellation of its banking licence, still claimed deduction under section 80P(2)(a)(i) on receipts said to be banking income. The Tribunal treated the claim as made in conscious disregard of the legal position because the assessee knew it could no longer carry on banking business and its auditors had recorded that the banking regime was no longer applicable. Section 176(3A) was held inapplicable because there was no discontinuance of business in the statutory sense. Full disclosure of the claim in the return did not establish a bona fide explanation, and the explanation remained unsubstantiated.</description>
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