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    <title>2026 (5) TMI 309 - ITAT MUMBAI</title>
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    <description>Penalty under section 270A for misreporting of income was considered unsustainable where the addition was based on an estimated commission rate of 5% applied to loan transactions, rather than on direct evidence of actual receipt. Income determined on estimate fell within the statutory exclusion from &quot;under-reported income&quot; in the relevant circumstances, and the Revenue did not establish which limb of section 270A(9) was said to apply. The assessee&#039;s disclosure in the return filed after notice under section 148, stated to be made to buy peace, was not treated as an admission of misreporting. Deletion of the penalty was therefore justified.</description>
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    <pubDate>Mon, 27 Apr 2026 00:00:00 +0530</pubDate>
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      <title>2026 (5) TMI 309 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=791107</link>
      <description>Penalty under section 270A for misreporting of income was considered unsustainable where the addition was based on an estimated commission rate of 5% applied to loan transactions, rather than on direct evidence of actual receipt. Income determined on estimate fell within the statutory exclusion from &quot;under-reported income&quot; in the relevant circumstances, and the Revenue did not establish which limb of section 270A(9) was said to apply. The assessee&#039;s disclosure in the return filed after notice under section 148, stated to be made to buy peace, was not treated as an admission of misreporting. Deletion of the penalty was therefore justified.</description>
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      <pubDate>Mon, 27 Apr 2026 00:00:00 +0530</pubDate>
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