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    <title>2026 (4) TMI 192 - ITAT BANGALORE</title>
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    <description>Penalty under Section 271(1)(c) of the Income-tax Act was not leviable because the quantum addition had already been admitted by the High Court on substantial questions of law, showing that the addition had not attained finality and remained debatable. On that footing, concealment of income or furnishing of inaccurate particulars could not be treated as established merely from the pending quantum dispute. The deletion of penalty was therefore upheld.</description>
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      <description>Penalty under Section 271(1)(c) of the Income-tax Act was not leviable because the quantum addition had already been admitted by the High Court on substantial questions of law, showing that the addition had not attained finality and remained debatable. On that footing, concealment of income or furnishing of inaccurate particulars could not be treated as established merely from the pending quantum dispute. The deletion of penalty was therefore upheld.</description>
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