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    <title>2021 (2) TMI 1134 - ITAT MUMBAI</title>
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    <description>Penalty under section 271(1)(c) was considered unsustainable where the assessee had disclosed the relevant particulars in the tax audit report and return, and the disallowance under section 43B arose only because the claim was not accepted in assessment. Mere rejection of a claim did not establish concealment of income or furnishing of inaccurate particulars. The minor mismatch between the return figures and AIR/26AS information was treated as insignificant, and no mala fide or contumacious conduct was found. On that basis, the penalty was deleted in favour of the assessee.</description>
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      <description>Penalty under section 271(1)(c) was considered unsustainable where the assessee had disclosed the relevant particulars in the tax audit report and return, and the disallowance under section 43B arose only because the claim was not accepted in assessment. Mere rejection of a claim did not establish concealment of income or furnishing of inaccurate particulars. The minor mismatch between the return figures and AIR/26AS information was treated as insignificant, and no mala fide or contumacious conduct was found. On that basis, the penalty was deleted in favour of the assessee.</description>
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