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    <title>2025 (2) TMI 1710 - ITAT SURAT</title>
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    <description>Penalty under section 271(1)(c) was held unsustainable where the assessee, following the mercantile system of accounting, had accounted only the duty drawback actually received and treated the balance as not received during the year. The difference between the accounts and Form 26AS did not, on these facts, show concealment of income or furnishing of inaccurate particulars because the relevant particulars were disclosed and the receipt was recorded on the basis adopted in the books. A mere addition arising from this mismatch was therefore insufficient to attract penalty, and the penalty was directed to be deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=467674</link>
      <description>Penalty under section 271(1)(c) was held unsustainable where the assessee, following the mercantile system of accounting, had accounted only the duty drawback actually received and treated the balance as not received during the year. The difference between the accounts and Form 26AS did not, on these facts, show concealment of income or furnishing of inaccurate particulars because the relevant particulars were disclosed and the receipt was recorded on the basis adopted in the books. A mere addition arising from this mismatch was therefore insufficient to attract penalty, and the penalty was directed to be deleted.</description>
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