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Section 270A

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Proposed Changes to the ITR-U Framework under Finance Bill 2026

Income Tax : Budget 2026 proposes allowing taxpayers to file an updated return even after receiving a reassessment notice under Section 148. Wh...

March 5, 2026 1713 Views 0 comment Print

Section 270A Penalty Quashed Because Incorrect Limb Was Invoked at Initiation

Income Tax : Misreporting under Section 270A(9) applies only to six specific circumstances. Where the assessment order does not clearly establi...

March 2, 2026 846 Views 0 comment Print

Penalty for Under-Reporting to Be Issued With Assessment, Not Separately

Income Tax : The law now proposes a single consolidated assessment-cum-penalty order for under-reporting of income, reducing multiple proceedin...

February 2, 2026 1455 Views 0 comment Print

FAQs on Penalty provisions under Income Tax Act, 1961

Income Tax : Detailed overview of penalties under various sections of the Income Tax Act, covering defaults in tax payment, reporting, document...

October 30, 2025 5391 Views 0 comment Print

Precision in Penalty: Why Misreporting Must Be Pinpointed Under Section 270A

Income Tax : Section 270A penalties must specify the exact misreporting clause. Vague notices invalidate penalties and can restore immunity und...

October 25, 2025 4476 Views 3 comments Print


Latest News


Budget 2024: Time-limit for filing appeals to Income Tax Appellate Tribunal

Income Tax : Explore amendments to section 253 of Income-tax Act, adjusting time limits for filing appeals to the Income Tax Appellate Tribunal...

July 23, 2024 12552 Views 0 comment Print


Latest Judiciary


No Penalty When Quantum Deleted: 270A Cannot Survive Without Addition

Income Tax : ITAT Mumbai deletes penalty under Section 270A as quantum addition was fully removed. Held that no under-reporting exists when ass...

April 18, 2026 54 Views 0 comment Print

Duty Drawback Taxable Only on Receipt – ITAT Deletes Addition & U/s 270A Penalty

Income Tax : The tribunal examined whether duty drawback should be taxed on accrual or actual receipt. It held that as per law, duty drawback i...

April 16, 2026 126 Views 0 comment Print

ITAT Pune: Interest on Bank Deposits Not Covered by Mutuality; Only Proportionate Expenses Allowed

Income Tax : ITAT held that interest earned on bank deposits is taxable and not covered by the principle of mutuality. The ruling confirms that...

April 13, 2026 159 Views 0 comment Print

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

Income Tax : The Tribunal restored the penalty matter as the quantum addition was sent back to the AO. It held that penalty must follow the out...

April 9, 2026 351 Views 0 comment Print

Debatable Issue, No Penalty – ITAT Deletes U/s 270A Penalty on Land Classification

Income Tax : The issue was penalty for misreporting on sale of land classified as capital asset. The Tribunal held the issue was debatable and ...

April 6, 2026 1407 Views 0 comment Print


Section 44AD Case Can’t Become Blanket Cash Addition; ITAT Surat Sets Aside ₹5.09 Cr Assessment

December 19, 2025 699 Views 0 comment Print

The ITAT held that additions based on incorrect and unreconciled bank data cannot be sustained. The assessment was remanded for fresh verification of actual cash deposits and credits.

Section 145A Cannot Be Used to Inflate Profits: ₹38.26 Lakh Addition Deleted

December 19, 2025 393 Views 0 comment Print

Mumbai ITAT ruled that Section 145A is a valuation provision, not a charging mechanism, and deleted a ₹38.26 lakh MODVAT/CENVAT addition, highlighting that proper accounting and reconciliation prevent artificial income.

Notional Interest on Interest-Free Advances Rejected Under Real Income Theory

December 19, 2025 519 Views 0 comment Print

The Tribunal reiterated that tax authorities cannot impose notional income merely because interest could have been charged. Commercial decisions on interest-free advances lie with the assessee, not the assessing officer.

IFE Content Is Not Royalty: ITAT Delhi Applies DTAA Override Deletes Tax on In-Flight Entertainment Fees

December 18, 2025 219 Views 0 comment Print

The issue was whether payments for supplying in-flight entertainment content constituted royalty. The Tribunal held that mere provision and processing of licensed content without transfer of copyright does not amount to royalty under the India-UK DTAA.

Delay of filing of appeal before CIT(A) not condoned as sufficient cause not shown

December 17, 2025 612 Views 0 comment Print

ITAT Indore held that delay of 560 days in filing of an appeal before CIT(A) rightly not condoned as assessee has failed to give satisfactory and bonafide explanation. Accordingly, delay not condoned as no sufficient cause shown.

Ancillary Software Services Protected Under DTAA as FTS Conditions Not Met

December 17, 2025 429 Views 0 comment Print

ITAT Mumbai ruled that ancillary software support services did not constitute FTS under the India–Singapore DTAA, deleting a ₹482.77 crore addition due to failure of the make available test.

Transfer Pricing Assessments Quashed as Time-Barred Despite DRP Directions

December 17, 2025 603 Views 0 comment Print

The tribunal held that assessments completed through the DRP mechanism remain subject to the outer time limit prescribed under section 153. The key takeaway is that section 144C does not extend or override statutory limitation periods.

No Further Section 14A Disallowance After Reasoned Suo-Motu Adjustment

December 16, 2025 582 Views 0 comment Print

The ITAT held that where investments are fully backed by substantial own funds and a rational suo-motu disallowance is made, Rule 8D cannot be mechanically invoked. The Revenue’s attempt to make an additional disallowance was rejected.

Section 271(1)(c) Penalty Proceedings Failed Because Levy Exceeded Scope of Notice

December 16, 2025 399 Views 0 comment Print

The ITAT held that penalty under Section 271(1)(c) fails where the notice alleged inaccurate particulars but the levy was based on concealment.

Bandwidth Charges Not Taxable as Royalty Under India-Singapore DTAA: ITAT Delhi

December 15, 2025 543 Views 0 comment Print

The Tribunal ruled that payments for IPL and MPLS bandwidth services do not constitute royalty under section 9(1)(vi) or Article 12(3) of the India-Singapore Tax Treaty, following consistent earlier rulings.

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