Professional-fee penalty requires substantiated claims and proven tax-deduction liability; unsupported claims may still attract penalty.

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....Penalty for inaccurate particulars in professional-fee claims requires substantiated expenditure and independent findings supporting concealment or inaccurate particulars. A payment characterised as professional fees but shown to be a loan advanced and repaid, with a corresponding receipt credited to profit and loss, is revenue neutral and does not support disallowance or penalty. Conversely, penalty remains justified where claimed payees deny receipt or payments remain unsubstantiated. Liability to deduct tax on professional fees depends on satisfying the statutory threshold based on gross receipts in the immediately preceding financial year; older receipt data alone is insufficient. Disallowance for non-deduction of tax does not, by itself, justify penalty.....