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    <title>2023 (5) TMI 1219 - ITAT DELHI</title>
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    <description>Penalty under section 271(1)(c) could not be sustained where the assessee had fully disclosed the domain registration receipts and the taxability of those receipts as royalty remained debatable. The quantum dispute had already been admitted by the High Court on a substantial question of law, showing that the issue was not finally settled. Mere disallowance of the claim in quantum proceedings did not establish concealment of income or furnishing of inaccurate particulars. The deletion of penalty was therefore upheld.</description>
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      <description>Penalty under section 271(1)(c) could not be sustained where the assessee had fully disclosed the domain registration receipts and the taxability of those receipts as royalty remained debatable. The quantum dispute had already been admitted by the High Court on a substantial question of law, showing that the issue was not finally settled. Mere disallowance of the claim in quantum proceedings did not establish concealment of income or furnishing of inaccurate particulars. The deletion of penalty was therefore upheld.</description>
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