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    <title>2025 (3) TMI 2184 - ITAT MUMBAI</title>
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    <description>Penalties cannot survive when the quantum additions forming their foundation have been deleted and no stay operates against that deletion. Penalty was therefore deleted in respect of those additions. Where alleged bogus purchases were retained only to the extent of an estimated profit element, the estimated nature of the addition did not, without more, support penalty; penalty on that addition was also deleted. The impugned penalties were consequently deleted because the underlying additions either no longer survived or rested solely on estimation.</description>
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      <description>Penalties cannot survive when the quantum additions forming their foundation have been deleted and no stay operates against that deletion. Penalty was therefore deleted in respect of those additions. Where alleged bogus purchases were retained only to the extent of an estimated profit element, the estimated nature of the addition did not, without more, support penalty; penalty on that addition was also deleted. The impugned penalties were consequently deleted because the underlying additions either no longer survived or rested solely on estimation.</description>
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