https://www.taxtmi.com/caselaws?id=779241 ITAT MUMBAI-AT deleted penalty under s.271(1)(c) and allowed the assessee's appeal. The tribunal held that recharacterisation of a loan as deemed dividend u/s 2(22)(e) - and a related s.40A(3) disallowance - did not prove furnishing of inaccurate particulars where relevant facts were on record and precedential decisions supported the assessee's position. The tribunal observed earlier judicial decisions existed before assessment and penalty orders, and noted the amount should be taxed in the hands of common shareholders; mere disallowance did not justify penalty. en-us Fri, 26 Sep 2025 00:00:00 +0530 Wed, 01 Oct 2025 09:07:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779241 ITAT MUMBAI-AT deleted penalty under s.271(1)(c) and allowed the assessee's appeal. The tribunal held that recharacterisation of a loan as deemed dividend u/s 2(22)(e) - and a related s.40A(3) disallowance - did not prove furnishing of inaccurate particulars where relevant facts were on record and precedential decisions supported the assessee's position. The tribunal observed earlier judicial decisions existed before assessment and penalty orders, and noted the amount should be taxed in the hands of common shareholders; mere disallowance did not justify penalty. Case-Laws Income Tax Fri, 26 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779241