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    <title>2026 (6) TMI 1128 - ITAT PUNE</title>
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    <description>A bona fide claim for education cess based on then-existing judicial precedent was noted as not constituting under-reporting for penalty purposes under section 270A(2)(a), especially where the later retrospective insertion of Explanation 3 to section 40(a)(ii) did not by itself make the earlier return false and the claim had not been allowed in assessment. The article also notes that disallowance under section 14A was held unsustainable where no exempt income was earned during the year, and the 01.04.2022 amendment to section 14A was treated as prospective and inapplicable to the year under appeal.</description>
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      <title>2026 (6) TMI 1128 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=793747</link>
      <description>A bona fide claim for education cess based on then-existing judicial precedent was noted as not constituting under-reporting for penalty purposes under section 270A(2)(a), especially where the later retrospective insertion of Explanation 3 to section 40(a)(ii) did not by itself make the earlier return false and the claim had not been allowed in assessment. The article also notes that disallowance under section 14A was held unsustainable where no exempt income was earned during the year, and the 01.04.2022 amendment to section 14A was treated as prospective and inapplicable to the year under appeal.</description>
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