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    <title>2025 (3) TMI 227 - BOMBAY HIGH COURT</title>
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    <description>Penalty under section 271(1)(c) of the Income-tax Act, 1961 was held unsustainable where a charitable trust claimed exemption under section 11 on the basis of a registration application already filed before the return and disclosed to the Revenue. The trust&#039;s claim was made on a bona fide understanding that registration would relate back to the commencement date, and the delay in grant of registration was not attributable to the assessee. On those disclosed primary facts, the claim could not be treated as concealment of income or furnishing of inaccurate particulars, and the penalty was deleted.</description>
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      <description>Penalty under section 271(1)(c) of the Income-tax Act, 1961 was held unsustainable where a charitable trust claimed exemption under section 11 on the basis of a registration application already filed before the return and disclosed to the Revenue. The trust&#039;s claim was made on a bona fide understanding that registration would relate back to the commencement date, and the delay in grant of registration was not attributable to the assessee. On those disclosed primary facts, the claim could not be treated as concealment of income or furnishing of inaccurate particulars, and the penalty was deleted.</description>
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