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    <title>2026 (7) TMI 1149 - ITAT DELHI</title>
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    <description>Penalty under Section 271(1)(c) was unsustainable where the notice did not specify whether concealment or inaccurate particulars was alleged, as the unstruck standard-form notice failed to communicate the precise charge. It was also not justified for a disallowance involving genuine employees&#039; provident fund expenditure and divergent judicial views, absent false disclosure or deliberate tax evasion. Penalty under Section 270A for a weighted deduction claim was invalid because the claim was based on information available at filing, material facts were disclosed, and neither the notice nor order identified the applicable under-reporting circumstance. The penalties were deleted or quashed.</description>
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      <description>Penalty under Section 271(1)(c) was unsustainable where the notice did not specify whether concealment or inaccurate particulars was alleged, as the unstruck standard-form notice failed to communicate the precise charge. It was also not justified for a disallowance involving genuine employees&#039; provident fund expenditure and divergent judicial views, absent false disclosure or deliberate tax evasion. Penalty under Section 270A for a weighted deduction claim was invalid because the claim was based on information available at filing, material facts were disclosed, and neither the notice nor order identified the applicable under-reporting circumstance. The penalties were deleted or quashed.</description>
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