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    <title>2026 (5) TMI 901 - ITAT AHMEDABAD</title>
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    <description>Penalty under section 270A was unsustainable where the additions arose from a disclosed and debatable claim on the character of expenditure. The dispute concerned whether loan processing charges and stamp duty were capital or revenue in nature, and whether preliminary expenses were allowable under section 35D. As the audited accounts disclosed the particulars and the controversy went only to eligibility and classification, the disallowance did not establish concealment, inaccurate particulars, under-reporting, or misreporting of income. The penalty was therefore deleted.</description>
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      <description>Penalty under section 270A was unsustainable where the additions arose from a disclosed and debatable claim on the character of expenditure. The dispute concerned whether loan processing charges and stamp duty were capital or revenue in nature, and whether preliminary expenses were allowable under section 35D. As the audited accounts disclosed the particulars and the controversy went only to eligibility and classification, the disallowance did not establish concealment, inaccurate particulars, under-reporting, or misreporting of income. The penalty was therefore deleted.</description>
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