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    <title>2025 (7) TMI 2019 - ITAT MUMBAI</title>
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    <description>Ad hoc disallowances in a search-related assessment under section 153C read with section 143(3) did not justify penalty under section 271(1)(c) where no incriminating material showed the expenditure claims were false or unrelated to business. The assessee had disclosed the expenditure in the return and profit and loss account, so the additions were treated as beyond the permissible scope of the unabated search assessment and did not establish concealment or furnishing of inaccurate particulars. Penalty was therefore not sustainable and was deleted, with the Revenue&#039;s appeal dismissed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=468928</link>
      <description>Ad hoc disallowances in a search-related assessment under section 153C read with section 143(3) did not justify penalty under section 271(1)(c) where no incriminating material showed the expenditure claims were false or unrelated to business. The assessee had disclosed the expenditure in the return and profit and loss account, so the additions were treated as beyond the permissible scope of the unabated search assessment and did not establish concealment or furnishing of inaccurate particulars. Penalty was therefore not sustainable and was deleted, with the Revenue&#039;s appeal dismissed.</description>
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