https://www.taxtmi.com/caselaws?id=465237 ITAT Mumbai allowed the assessee's appeals and deleted penalties levied under ss. 271(1)(c), 270A and 271AAB. It held that penalty cannot be sustained where additions on salaries, wages and administrative expenses are made purely on an ad hoc/estimated basis without identifying specific bogus entries. Suo motu disallowance of interest and excess depreciation in the return filed u/s 153A was not shown to arise from incriminating material found in search, so Explanation 5A to s. 271(1)(c) and s. 271AAB were inapplicable. The assessee had furnished a bona fide explanation with full material facts, excluding "under-reporting" under s. 270A. Mere defects in vouchers and unverified adjustments, without demonstration of falsity or search-based discovery, were held insufficient for sustaining any of the impugned penalties. en-us Wed, 30 Jul 2025 00:00:00 +0530 Wed, 10 Dec 2025 17:35:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465237 ITAT Mumbai allowed the assessee's appeals and deleted penalties levied under ss. 271(1)(c), 270A and 271AAB. It held that penalty cannot be sustained where additions on salaries, wages and administrative expenses are made purely on an ad hoc/estimated basis without identifying specific bogus entries. Suo motu disallowance of interest and excess depreciation in the return filed u/s 153A was not shown to arise from incriminating material found in search, so Explanation 5A to s. 271(1)(c) and s. 271AAB were inapplicable. The assessee had furnished a bona fide explanation with full material facts, excluding "under-reporting" under s. 270A. Mere defects in vouchers and unverified adjustments, without demonstration of falsity or search-based discovery, were held insufficient for sustaining any of the impugned penalties. Case-Laws Income Tax Wed, 30 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465237