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    <title>2025 (4) TMI 206 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai ruled in favor of the assessee regarding penalties under sections 271(1)(c) and 270A. For section 271(1)(c), the tribunal held that no penalty can be imposed when the AO makes no addition or disallowance to income disclosed pursuant to section 148 notice, citing precedents from Calcutta HC and coordinate bench decisions. For section 270A penalty, the tribunal found that the AO has discretion in imposing penalties for under-reporting, and should have exercised discretion favorably given the assessee was a retired MTNL employee who relied on tax return preparer and voluntarily made disallowances with tax payment. Both penalties were deleted and the appeal was allowed.</description>
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    <pubDate>Tue, 25 Mar 2025 00:00:00 +0530</pubDate>
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      <title>2025 (4) TMI 206 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=768292</link>
      <description>ITAT Mumbai ruled in favor of the assessee regarding penalties under sections 271(1)(c) and 270A. For section 271(1)(c), the tribunal held that no penalty can be imposed when the AO makes no addition or disallowance to income disclosed pursuant to section 148 notice, citing precedents from Calcutta HC and coordinate bench decisions. For section 270A penalty, the tribunal found that the AO has discretion in imposing penalties for under-reporting, and should have exercised discretion favorably given the assessee was a retired MTNL employee who relied on tax return preparer and voluntarily made disallowances with tax payment. Both penalties were deleted and the appeal was allowed.</description>
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      <pubDate>Tue, 25 Mar 2025 00:00:00 +0530</pubDate>
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