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    <title>2023 (4) TMI 1404 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai set aside penalty u/s 271(1)(c) imposed on assessee for alleged accommodation entries. The tribunal held that the penalty notice was invalid as the AO failed to specify whether it was for concealing income particulars or furnishing inaccurate particulars, following the precedent in Md. Farhan A Sheikh case. Additionally, since the entire addition was based on estimation and guesswork rather than concrete evidence of concealment or inaccurate particulars, the penalty was unsustainable. The addition was progressively reduced from 100% by AO to 2% by CIT(A) to 0.15% by the tribunal, confirming its estimative nature.</description>
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      <description>ITAT Mumbai set aside penalty u/s 271(1)(c) imposed on assessee for alleged accommodation entries. The tribunal held that the penalty notice was invalid as the AO failed to specify whether it was for concealing income particulars or furnishing inaccurate particulars, following the precedent in Md. Farhan A Sheikh case. Additionally, since the entire addition was based on estimation and guesswork rather than concrete evidence of concealment or inaccurate particulars, the penalty was unsustainable. The addition was progressively reduced from 100% by AO to 2% by CIT(A) to 0.15% by the tribunal, confirming its estimative nature.</description>
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