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    <title>2026 (5) TMI 298 - ITAT DELHI</title>
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    <description>Penalty under section 271(1)(c) of the Income-tax Act was not leviable on additions arising from disallowance of depreciation and section 14A disallowance because the assessment adjustments did not show concealment of income or furnishing of inaccurate particulars. The section 14A issue was treated as a legal question, and the assessee had made a suo motu disallowance in the return. A mere rejection of the claim, or the adoption of a different quantum view, was held insufficient to sustain penalty where the relevant particulars were disclosed and the claim was not found false. The deletion of penalty was upheld.</description>
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      <link>https://www.taxtmi.com/caselaws?id=791096</link>
      <description>Penalty under section 271(1)(c) of the Income-tax Act was not leviable on additions arising from disallowance of depreciation and section 14A disallowance because the assessment adjustments did not show concealment of income or furnishing of inaccurate particulars. The section 14A issue was treated as a legal question, and the assessee had made a suo motu disallowance in the return. A mere rejection of the claim, or the adoption of a different quantum view, was held insufficient to sustain penalty where the relevant particulars were disclosed and the claim was not found false. The deletion of penalty was upheld.</description>
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