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    <title>2026 (6) TMI 138 - ITAT DELHI</title>
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    <description>Delay in filing the first appellate appeal was condoned where the order was uploaded on the portal, not physically served, and the assessee acted after learning of the demand. Penalty under section 271(1)(c) could not survive on the interest disallowance under section 36(1)(iii) because the underlying quantum addition had already been deleted. Penalty was also deleted on the subsidy reclassification issue because the capital-versus-revenue characterisation was debatable and the claim was made bona fide with full disclosure. The appeal succeeded and the penalty order was set aside.</description>
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      <link>https://www.taxtmi.com/caselaws?id=792757</link>
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