https://www.taxtmi.com/caselaws?id=462513 ITAT Mumbai held that penalty under Section 271(1)(c) cannot be imposed when additions are made on estimated basis, as mere disallowance of expenses does not constitute concealment of income. The Tribunal ruled that assessment under Section 153A cannot be reopened merely on change of opinion, particularly when all material facts were disclosed during original proceedings. Regarding expense allocation between business income and house property income, the Tribunal found that expenses related to common area maintenance, security, and promotional activities were properly classified as business expenses since the assessee provided additional services to tenants beyond rental activity. The Tribunal restricted various disallowances and upheld CIT(A)'s deletions of several additions, confirming that expenses incurred for composite business operations should not be allocated to rental income. en-us Thu, 06 Oct 2016 00:00:00 +0530 Fri, 27 Jun 2025 15:06:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462513 ITAT Mumbai held that penalty under Section 271(1)(c) cannot be imposed when additions are made on estimated basis, as mere disallowance of expenses does not constitute concealment of income. The Tribunal ruled that assessment under Section 153A cannot be reopened merely on change of opinion, particularly when all material facts were disclosed during original proceedings. Regarding expense allocation between business income and house property income, the Tribunal found that expenses related to common area maintenance, security, and promotional activities were properly classified as business expenses since the assessee provided additional services to tenants beyond rental activity. The Tribunal restricted various disallowances and upheld CIT(A)'s deletions of several additions, confirming that expenses incurred for composite business operations should not be allocated to rental income. Case-Laws Income Tax Thu, 06 Oct 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462513