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Section 270A

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FAQs on Penalty provisions under Income Tax Act, 1961

Income Tax : This guide explains when penalties can be imposed under various provisions of the Income-tax Act, 1961. It also outlines the appli...

June 22, 2026 5895 Views 0 comment Print

ITAT Deletes Section 270A Penalty as Estimated Addition Cannot Justify Penalty

Income Tax : ITAT Mumbai held that penalty under Section 270A cannot be levied merely because income was estimated after rejection of books. Si...

June 20, 2026 342 Views 0 comment Print

Specified Domestic Transaction- Penalty for Concealment of Income

Income Tax : The article explains how transactions between associated domestic entities exceeding ₹20 crore must comply with arm's length pri...

June 15, 2026 57930 Views 1 comment Print

ITAT Deletes Section 270A Penalty Due to Defective Notice and Bona Fide Reliance on Form 16

Income Tax : The Tribunal ruled that non-specification of the precise statutory charge under sections 270A(2) and 270A(9) violated principles o...

May 15, 2026 774 Views 0 comment Print

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 2313 Views 0 comment 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 14589 Views 0 comment Print


Latest Judiciary


Cost-to-Cost Overseas Reimbursements Without Profit Element Not Taxable as FTS: ITAT Delhi

Income Tax : ITAT Delhi held that IT, salary and travel reimbursements without any profit element were not taxable and deleted the disallowance...

July 4, 2026 141 Views 0 comment Print

DCF Share Valuation Accepted as AO Could Not Replace Prescribed Method with NAV

Income Tax : ITAT held that an Assessing Officer cannot substitute the DCF method chosen under Rule 11UA with the NAV method without legal just...

July 3, 2026 183 Views 0 comment Print

Indexed Cost Can’t Be Reduced When Entire Property Rights Are Surrendered: ITAT Pune

Income Tax : ITAT held ₹33 crore settled rights over the entire land, allowing full indexed acquisition cost and rejecting proportionate rest...

July 3, 2026 186 Views 0 comment Print

ITAT Delhi Excludes TPO Comparables for Functional Dissimilarity

Income Tax : ITAT excluded EDCIL, Just Dial, Info Edge and India Exposition Mart as transfer pricing comparables due to functional differences ...

July 1, 2026 153 Views 0 comment Print

ITAT Deletes Sections 270A & 271AAB Penalty as Notice Lacked Specific Charge

Income Tax : The Tribunal ruled that a penalty notice lacking a specific allegation of under-reporting, misreporting, or the applicable clause ...

July 1, 2026 318 Views 0 comment Print


Interest on delayed remittance of TDS not deductible as business expense u/s. 37(1)

December 19, 2025 537 Views 0 comment Print

ITAT Hyderabad held that interest paid on account of delayed remittance of TDS cannot be treated as business expenditure under section 37(1) of the Income Tax Act. Accordingly, order disallowing the same is upheld.

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

December 19, 2025 918 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 555 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 720 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 261 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 801 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 555 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 831 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 693 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 489 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.

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