Penalty U/s 270A Held Premature – ITAT Bangalore Restores Matter Pending Quantum Outcome

Ankitha Shetty Vs ITO (ITAT Bangalore) The assessee was subjected to penalty under Section 270A (₹8.62 lakh @ 200%) for alleged under-reporting/misreporting of income arising from foreign salary claimed as non-taxable under the India-US DTAA. The AO and CIT(A) upheld the penalty. However, it was brought to the Tribunal’s notice that the quantum addition itself had already been set aside by ITAT and remanded back to the AO for fresh adjudication in accordance with DTAA provisions. The ITAT Bangalore held that since the quantum proceedings are still pending, the penalty proceedings cannot be...