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    <title>2025 (8) TMI 671 - ITAT DELHI</title>
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    <description>Penalty under section 271(1)(c) was held unsustainable where cash deposits were treated as business receipts under the presumptive scheme in section 44AD. The assessment addition by itself did not justify concealment penalty, because quantum and penalty proceedings are separate and the existence of an addition does not automatically establish inaccurate particulars or concealment. On the material considered, the receipts were capable of treatment as business transactions, so the penalty was deleted and relief was granted to the assessee.</description>
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      <description>Penalty under section 271(1)(c) was held unsustainable where cash deposits were treated as business receipts under the presumptive scheme in section 44AD. The assessment addition by itself did not justify concealment penalty, because quantum and penalty proceedings are separate and the existence of an addition does not automatically establish inaccurate particulars or concealment. On the material considered, the receipts were capable of treatment as business transactions, so the penalty was deleted and relief was granted to the assessee.</description>
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