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    <title>2025 (11) TMI 2032 - ITAT HYDERABAD</title>
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    <description>Penalty for under-reporting was not leviable where the taxpayer&#039;s explanation was bona fide, supported by full disclosure of material facts, and accepted as genuine under section 270A(6). Substantial self-assessment tax had been paid before reopening, capital-gains income was fully disclosed in response to notice, and the returned income was accepted without adjustment. Ambiguity over taxability of jointly held property under a joint-development arrangement also supported the absence of intent to under-report. The disclosed income therefore fell within the statutory exclusion, requiring deletion of the penalty.</description>
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      <description>Penalty for under-reporting was not leviable where the taxpayer&#039;s explanation was bona fide, supported by full disclosure of material facts, and accepted as genuine under section 270A(6). Substantial self-assessment tax had been paid before reopening, capital-gains income was fully disclosed in response to notice, and the returned income was accepted without adjustment. Ambiguity over taxability of jointly held property under a joint-development arrangement also supported the absence of intent to under-report. The disclosed income therefore fell within the statutory exclusion, requiring deletion of the penalty.</description>
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