https://www.taxtmi.com/highlights?id=98881 The ITAT held that penalty under section 271(1)(c) was unsustainable because the dispute concerned only the head of income and the allowability of deduction on disclosed facts, not concealment or furnishing of inaccurate particulars. The assessee's claim for full section 54 relief was accepted on the merits, and the joint reinvestment with her son had been disclosed to the department. Relying on Manjunatha Cotton and Reliance Petroproducts, the Tribunal held that a disallowed claim or a claim under a different head does not by itself justify penalty. The penalty was deleted. en-us Fri, 17 Apr 2026 08:21:23 +0530 Fri, 17 Apr 2026 08:21:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=98881 The ITAT held that penalty under section 271(1)(c) was unsustainable because the dispute concerned only the head of income and the allowability of deduction on disclosed facts, not concealment or furnishing of inaccurate particulars. The assessee's claim for full section 54 relief was accepted on the merits, and the joint reinvestment with her son had been disclosed to the department. Relying on Manjunatha Cotton and Reliance Petroproducts, the Tribunal held that a disallowed claim or a claim under a different head does not by itself justify penalty. The penalty was deleted. Highlights Income Tax Fri, 17 Apr 2026 08:21:23 +0530 https://www.taxtmi.com/highlights?id=98881