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    <title>2025 (11) TMI 1074 - ITAT MUMBAI</title>
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    <description>ITAT held that penalty under section 270A could not be imposed where the assessee had fully disclosed the loss and the dispute concerned only the legal characterisation of that loss as speculative versus non-speculative. The tribunal agreed with the appeal body that there was no under-reporting of income or culpable conduct; the assessment merely reclassified the loss without increasing tax for the year. Consequently, the penalty was deleted and the order of the appellate authority upholding cancellation of the penalty was affirmed in favour of the assessee.</description>
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      <title>2025 (11) TMI 1074 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=781606</link>
      <description>ITAT held that penalty under section 270A could not be imposed where the assessee had fully disclosed the loss and the dispute concerned only the legal characterisation of that loss as speculative versus non-speculative. The tribunal agreed with the appeal body that there was no under-reporting of income or culpable conduct; the assessment merely reclassified the loss without increasing tax for the year. Consequently, the penalty was deleted and the order of the appellate authority upholding cancellation of the penalty was affirmed in favour of the assessee.</description>
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