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    <title>2026 (6) TMI 819 - ITAT CHENNAI</title>
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    <description>A claim that an addition represented exempt agricultural income did not protect the assessee from penalty under section 271(1)(c) where the income was omitted from the original return and from the return filed after notice under section 148, and the explanation remained unsupported by any documentary evidence. The Tribunal noted that a bare assertion of having made the disclosure to buy peace with the Department was insufficient. In the absence of proof that the explanation was bona fide and fully substantiated, Explanation 1 to section 271(1)(c) applied and deemed the addition to be concealed income, so the penalty was sustained.</description>
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      <title>2026 (6) TMI 819 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=793438</link>
      <description>A claim that an addition represented exempt agricultural income did not protect the assessee from penalty under section 271(1)(c) where the income was omitted from the original return and from the return filed after notice under section 148, and the explanation remained unsupported by any documentary evidence. The Tribunal noted that a bare assertion of having made the disclosure to buy peace with the Department was insufficient. In the absence of proof that the explanation was bona fide and fully substantiated, Explanation 1 to section 271(1)(c) applied and deemed the addition to be concealed income, so the penalty was sustained.</description>
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