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    <title>2025 (12) TMI 869 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai-AT dismissed the revenue&#039;s appeal and upheld deletion of penalty u/s 271(1)(c). It held that no concealment or furnishing of inaccurate particulars was established. In respect of impairment loss on fixed assets, the assessee had already suo motu disallowed the amount in the return, leaving no basis for further disallowance or penalty. The &quot;service tax receivable&quot; was correctly treated as current-year expenditure on input services charged to the P&amp;L, not a mere provision. Alleged &quot;unaccounted revenue&quot; was actually advance subscription income for the next year under the mercantile system, duly disclosed as revenue received in advance. Quantum additions attaining finality did not justify penalty.</description>
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      <link>https://www.taxtmi.com/caselaws?id=783329</link>
      <description>ITAT Mumbai-AT dismissed the revenue&#039;s appeal and upheld deletion of penalty u/s 271(1)(c). It held that no concealment or furnishing of inaccurate particulars was established. In respect of impairment loss on fixed assets, the assessee had already suo motu disallowed the amount in the return, leaving no basis for further disallowance or penalty. The &quot;service tax receivable&quot; was correctly treated as current-year expenditure on input services charged to the P&amp;L, not a mere provision. Alleged &quot;unaccounted revenue&quot; was actually advance subscription income for the next year under the mercantile system, duly disclosed as revenue received in advance. Quantum additions attaining finality did not justify penalty.</description>
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