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    <title>2026 (7) TMI 489 - ITAT JAIPUR</title>
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    <description>Penalty for concealment was held unsustainable where the assessee had already filed a return under section 139 and later disclosed long-term capital gains in a revised computation during reassessment. Explanation 3 to section 271(1)(c) was found inapplicable because it operates where no return is filed within the prescribed time and the return is furnished only after notice under section 148. On those facts, the later disclosure in reassessment proceedings did not amount to concealment or furnishing inaccurate particulars, so penalty was not justified and was to be deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=794603</link>
      <description>Penalty for concealment was held unsustainable where the assessee had already filed a return under section 139 and later disclosed long-term capital gains in a revised computation during reassessment. Explanation 3 to section 271(1)(c) was found inapplicable because it operates where no return is filed within the prescribed time and the return is furnished only after notice under section 148. On those facts, the later disclosure in reassessment proceedings did not amount to concealment or furnishing inaccurate particulars, so penalty was not justified and was to be deleted.</description>
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