https://www.taxtmi.com/caselaws?id=767492 Concurrent factual findings on reassessment under section 147 did not give rise to a substantial question of law because the Tribunal and first appellate authority found, on the record, that the assessee's statutory filings and audit report matched and no perversity was shown. The addition therefore could not be reopened on that basis. Disallowance under Explanation 1 to section 37(1) was also unwarranted because the record did not establish that any penalty expenditure had been claimed, or that the expenditure related to an actually illegal act attracting the Explanation. In the absence of foundational facts, the disallowance was unsustainable and the Tribunal's deletion of the addition was upheld. en-us Tue, 11 Mar 2025 00:00:00 +0530 Wed, 19 Mar 2025 06:45:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767492 Concurrent factual findings on reassessment under section 147 did not give rise to a substantial question of law because the Tribunal and first appellate authority found, on the record, that the assessee's statutory filings and audit report matched and no perversity was shown. The addition therefore could not be reopened on that basis. Disallowance under Explanation 1 to section 37(1) was also unwarranted because the record did not establish that any penalty expenditure had been claimed, or that the expenditure related to an actually illegal act attracting the Explanation. In the absence of foundational facts, the disallowance was unsustainable and the Tribunal's deletion of the addition was upheld. Case-Laws Income Tax Tue, 11 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767492