https://www.taxtmi.com/caselaws?id=464219 ITAT MUMBAI - AT dismissed Revenue's appeals and upheld deletion of penalty under s.271(1)(c). Background information from the Government of India and French authorities regarding undisclosed HSBC Geneva accounts led to additions; however CIT(A) deleted the s.69A addition for AY 2006-07 on merits and for AY 2007-08 found no reopening under s.147, noting the assessee paid tax on the additional income on 31.01.2011 and had filed a revised return before issuance of s.148 notice. With deletions and pre-notice tax payment, penalty was not sustainable. en-us Fri, 29 Jul 2022 00:00:00 +0530 Sat, 11 Oct 2025 20:45:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464219 ITAT MUMBAI - AT dismissed Revenue's appeals and upheld deletion of penalty under s.271(1)(c). Background information from the Government of India and French authorities regarding undisclosed HSBC Geneva accounts led to additions; however CIT(A) deleted the s.69A addition for AY 2006-07 on merits and for AY 2007-08 found no reopening under s.147, noting the assessee paid tax on the additional income on 31.01.2011 and had filed a revised return before issuance of s.148 notice. With deletions and pre-notice tax payment, penalty was not sustainable. Case-Laws Income Tax Fri, 29 Jul 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464219