Penalty for Underreporting Reopened Due to Unexamined Reasonable Cause

Unique Insurance Company Vs ITO (ITAT Chandigarh)

The assessee filed appeals for Assessment Years 2018–19 to 2020–21 challenging the confirmation of penalties levied under Section 270A of the Income Tax Act. As the facts and issues were identical across all years, the Tribunal examined the appeal for AY 2018–19 as the lead case. The penalty of ₹5,46,590 was imposed by the Assessing Officer and confirmed by the Commissioner of Income Tax (Appeals), NFAC, for alleged underreporting of income.

The assessee had not filed a regular return of income under Section 139(1).

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