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    <title>2023 (11) TMI 547 - BOMBAY HIGH COURT</title>
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    <description>The Bombay HC upheld ITAT&#039;s decision to delete penalty under Section 271(1)(c) imposed on the assessee. The court found that disallowances made by AO were due to difference of opinion between assessee and AO, not concealment of income or furnishing inaccurate particulars. The assessee had transparently disclosed all details of expenditure and income in the return. Following Supreme Court precedent in Reliance Petroproducts case, the court held that mere disagreement between assessee&#039;s claim and AO&#039;s view does not warrant penalty imposition, as accepting revenue&#039;s contention would result in penalty for every disallowed claim.</description>
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      <link>https://www.taxtmi.com/caselaws?id=445656</link>
      <description>The Bombay HC upheld ITAT&#039;s decision to delete penalty under Section 271(1)(c) imposed on the assessee. The court found that disallowances made by AO were due to difference of opinion between assessee and AO, not concealment of income or furnishing inaccurate particulars. The assessee had transparently disclosed all details of expenditure and income in the return. Following Supreme Court precedent in Reliance Petroproducts case, the court held that mere disagreement between assessee&#039;s claim and AO&#039;s view does not warrant penalty imposition, as accepting revenue&#039;s contention would result in penalty for every disallowed claim.</description>
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