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    <title>2021 (9) TMI 1024 - ITAT MUMBAI</title>
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    <description>The Tribunal upheld the Commissioner (Appeals)&#039; decision and dismissed the appeals, ruling that the penalties imposed under section 271(c) of the Income Tax Act for three assessment years were unwarranted. The Tribunal emphasized that the inability to prove the source of purchases did not automatically imply inaccurate particulars of income, as the additions were based on estimation and various factors could contribute to the lack of proof. Therefore, the penalties were deemed unjustified, and the assessee&#039;s appeals were rejected.</description>
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      <title>2021 (9) TMI 1024 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=412679</link>
      <description>The Tribunal upheld the Commissioner (Appeals)&#039; decision and dismissed the appeals, ruling that the penalties imposed under section 271(c) of the Income Tax Act for three assessment years were unwarranted. The Tribunal emphasized that the inability to prove the source of purchases did not automatically imply inaccurate particulars of income, as the additions were based on estimation and various factors could contribute to the lack of proof. Therefore, the penalties were deemed unjustified, and the assessee&#039;s appeals were rejected.</description>
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      <pubDate>Thu, 16 Sep 2021 00:00:00 +0530</pubDate>
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