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    <title>2014 (7) TMI 82 - ITAT DELHI</title>
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    <description>Penalty under section 271(1)(c) was held unsustainable where the assessee had fully disclosed the material facts and the dispute concerned only the legal acceptability of the claim. For the reimbursement of expenses received from the parent company, the addition arose from the assessee&#039;s own disclosure and revised computation, with no indication of detection by the Assessing Officer, so concealment or inaccurate particulars was not established. For the long-term capital loss claim based on an agreement to sell land, the underlying transaction was fully disclosed and the issue was whether the claim was legally allowable, not whether facts were concealed. A disallowed claim in quantum proceedings did not, by itself, justify penalty.</description>
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      <link>https://www.taxtmi.com/caselaws?id=249045</link>
      <description>Penalty under section 271(1)(c) was held unsustainable where the assessee had fully disclosed the material facts and the dispute concerned only the legal acceptability of the claim. For the reimbursement of expenses received from the parent company, the addition arose from the assessee&#039;s own disclosure and revised computation, with no indication of detection by the Assessing Officer, so concealment or inaccurate particulars was not established. For the long-term capital loss claim based on an agreement to sell land, the underlying transaction was fully disclosed and the issue was whether the claim was legally allowable, not whether facts were concealed. A disallowed claim in quantum proceedings did not, by itself, justify penalty.</description>
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