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2024 (4) TMI 1113 - ITAT PUNEPenalty u/s. 270A - Under-reporting of income / Mis-reporting - taxpayer herein has been found not to have disclosed it’s interest income/ interest on income tax refunds during the course of quantum assessment - HELD THAT:- We find from the assessee’s corresponding audited books [including P & L A/c] read with details of indirect incomes as well as the ledger(s) that it had duly included the foregoing interest in the indirect income head duly forming part of the computation submitted in quantum proceedings. Revenue at this stage vehemently argued that the lower authorities may be directed to verify this alleged clinching fact. No reason to accept the Revenue’s remand prayer once it is found that all these assessee’s details duly form part of the case file all along right from the course of assessment to the impugned penalty proceedings. Also in Reliance Petro Products [2010 (3) TMI 80 - SUPREME COURT] that quantum and penalty are parallel proceedings wherein any addition made in the course of former does not ipso facto attract latter provision. We accordingly find it a fit case to delete the impugned penalty in very terms. Assessee’s appeal is allowed.
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