Section 270A Penalty cannot be imposed for Disallowance of Legal Claim: ITAT Delhi

SAS Fashions Pvt. Ltd. Vs DCIT (ITAT Delhi) Penalty under Section 270A Deleted for Mere Wrong Claim – ITAT Delhi The Delhi ITAT deleted penalty levied under Section 270A on disallowance of depreciation claimed against rental income. The Tribunal held that the taxpayer had furnished all particulars of income and made full disclosure of facts, and the dispute involved only a legal issue regarding allowability of depreciation. It was observed that the Assessing Officer loosely applied the concepts of “under-reporting” and “misreporting”, without specifying the applicable limb of Section...