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    <title>2025 (7) TMI 123 - ITAT MUMBAI</title>
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    <description>Penalty for non-disclosure of foreign bank accounts was held unsustainable where the accounts and related income had already been disclosed in the husband&#039;s returns, the assessee later reflected them in her updated return, and she produced bank statements, source details, and supporting returns during penalty proceedings. The lapse was treated as inadvertent and based on a bona fide belief, not wilful concealment. As the revenue did not rebut the explanation or establish that the assessee was the actual beneficial owner of the assets or income, the penalty provision was not applied. The penalty was deleted.</description>
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      <description>Penalty for non-disclosure of foreign bank accounts was held unsustainable where the accounts and related income had already been disclosed in the husband&#039;s returns, the assessee later reflected them in her updated return, and she produced bank statements, source details, and supporting returns during penalty proceedings. The lapse was treated as inadvertent and based on a bona fide belief, not wilful concealment. As the revenue did not rebut the explanation or establish that the assessee was the actual beneficial owner of the assets or income, the penalty provision was not applied. The penalty was deleted.</description>
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