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    <title>2026 (9) TMI 1392 - ITAT PUNE</title>
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    <description>Penalty for under-reporting of income does not apply where a Health and Education Cess deduction claim was bona fide when made, supported by favourable judicial decisions including an earlier decision involving the assessee, and later became inadmissible due to retrospective clarification that tax includes surcharge and cess. The claim was voluntarily withdrawn during assessment following the retrospective insertion of Explanation 3 to section 40(a)(ii). Applying coordinate-bench decisions, the penalty under section 270A was directed to be deleted.</description>
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