Section 270A penalty cannot survive if underlying quantum addition is deleted

JCIT [OSD] Vs IGT Solution Pvt Ltd (ITAT Delhi) Foundation is removed, the Superstructure cannot Survive- Section 270A Levy Has No Legs: ITAT Delhi Deletes Penalty After Quantum Addition Is Wiped Out ITAT Delhi held that a Section 270A penalty cannot survive once the underlying quantum addition is deleted. Applying the principle sublato fundamento cadit opus, the Tribunal ruled that penalties have no independent existence and must fall when the foundational tax adjustment is annulled. With the AY 2017-18 addition removed, the associated penalty was automatically deleted, leading to dismissal o...