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    <title>2026 (9) TMI 1517 - ITAT MUMBAI</title>
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    <description>Estimated disallowances of alleged inflated purchases, where the extent of inflation is unproved, do not by themselves establish concealment for penalty under section 271(1)(c); penalty deletions were sustained. Documentary support for purchase claims, including invoices, vehicle details and ledgers, prevents their characterisation as wholly unsubstantiated expenditure for misreporting under section 270A(9)(c), although the taxpayer&#039;s explanation did not qualify for the section 270A(6) exception; penalty deletions were sustained. A separate section 271AAC penalty on cash received back from suppliers does not preclude a section 270A penalty absent a one-to-one correlation with the estimated purchase-inflation addition.</description>
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      <link>https://www.taxtmi.com/caselaws?id=799491</link>
      <description>Estimated disallowances of alleged inflated purchases, where the extent of inflation is unproved, do not by themselves establish concealment for penalty under section 271(1)(c); penalty deletions were sustained. Documentary support for purchase claims, including invoices, vehicle details and ledgers, prevents their characterisation as wholly unsubstantiated expenditure for misreporting under section 270A(9)(c), although the taxpayer&#039;s explanation did not qualify for the section 270A(6) exception; penalty deletions were sustained. A separate section 271AAC penalty on cash received back from suppliers does not preclude a section 270A penalty absent a one-to-one correlation with the estimated purchase-inflation addition.</description>
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