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    <title>2026 (4) TMI 1038 - ITAT KOLKATA</title>
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    <description>Penalty under section 270A of the Income-tax Act was deleted because the estate could not validly file the return before probate was granted to the executors. The omission was treated as reasonable and bona fide, since the income was ultimately disclosed in Form 26AS with tax deducted at source and all material facts were available. In these circumstances, section 270A(6) applied, so the income was not to be treated as unreported and under-reporting penalty was unsustainable.</description>
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