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    <title>2026 (8) TMI 1635 - ITAT MUMBAI</title>
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    <description>Penalty for furnishing inaccurate particulars requires an independently established default; a statutory disallowance alone is insufficient. A professional-fee debit corresponding to loan repayment and matching professional receipts was revenue neutral and could not support penalty where it was treated as a loan transaction rather than unexplained credit. Penalty remained applicable to professional-fee claims for which recipients denied payment or supporting evidence was not provided. For tax-deduction disallowance, an individual&#039;s or HUF&#039;s obligation to deduct tax depends on preceding-year gross professional receipts exceeding the prescribed threshold. Unverified reliance on receipts from an earlier year did not disprove the claimed absence of that obligation, so penalty could not rest on that disallowance.</description>
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      <link>https://www.taxtmi.com/caselaws?id=797761</link>
      <description>Penalty for furnishing inaccurate particulars requires an independently established default; a statutory disallowance alone is insufficient. A professional-fee debit corresponding to loan repayment and matching professional receipts was revenue neutral and could not support penalty where it was treated as a loan transaction rather than unexplained credit. Penalty remained applicable to professional-fee claims for which recipients denied payment or supporting evidence was not provided. For tax-deduction disallowance, an individual&#039;s or HUF&#039;s obligation to deduct tax depends on preceding-year gross professional receipts exceeding the prescribed threshold. Unverified reliance on receipts from an earlier year did not disprove the claimed absence of that obligation, so penalty could not rest on that disallowance.</description>
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