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    <title>2026 (5) TMI 1463 - ITAT PUNE</title>
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    <description>Penalty under section 271(1)(c) was held unsustainable where the assessee had declared gross receipts under the presumptive scheme in section 44AD. Since the accepted receipts were treated as sufficient to cover business expenditure and the scheme did not require regular books of account, the credit card payments were regarded as business outgoings sourced from declared receipts. On that basis, the addition treating the payments as unexplained could not support penalty, and the penalty was deleted in favour of the assessee.</description>
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      <description>Penalty under section 271(1)(c) was held unsustainable where the assessee had declared gross receipts under the presumptive scheme in section 44AD. Since the accepted receipts were treated as sufficient to cover business expenditure and the scheme did not require regular books of account, the credit card payments were regarded as business outgoings sourced from declared receipts. On that basis, the addition treating the payments as unexplained could not support penalty, and the penalty was deleted in favour of the assessee.</description>
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