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    <title>2015 (12) TMI 502 - ITAT MUMBAI</title>
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    <description>The Tribunal allowed the assessee&#039;s appeal, concluding that the penalty under section 271(1)(c) was not justified for the disputed amount of Rs. 2,77,00,000. The Tribunal emphasized that the difference in opinion between the Assessing Officer and CIT(A) did not warrant penalty imposition, as the assessee acted transparently and offered the income for taxation in the subsequent year following the resolution of disputes. The decision was based on the principle that penalty should not be imposed in cases of genuine differences in tax treatment, where the assessee acted in good faith and challenged tax assessments.</description>
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    <pubDate>Thu, 08 Oct 2015 00:00:00 +0530</pubDate>
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      <title>2015 (12) TMI 502 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=269198</link>
      <description>The Tribunal allowed the assessee&#039;s appeal, concluding that the penalty under section 271(1)(c) was not justified for the disputed amount of Rs. 2,77,00,000. The Tribunal emphasized that the difference in opinion between the Assessing Officer and CIT(A) did not warrant penalty imposition, as the assessee acted transparently and offered the income for taxation in the subsequent year following the resolution of disputes. The decision was based on the principle that penalty should not be imposed in cases of genuine differences in tax treatment, where the assessee acted in good faith and challenged tax assessments.</description>
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      <pubDate>Thu, 08 Oct 2015 00:00:00 +0530</pubDate>
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