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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 12549 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 156 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 348 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


CUP Method Rejection Unwarranted for Uniform Hourly Charges to AEs & Third Parties

November 4, 2023 453 Views 0 comment Print

ITAT that as long as the charges for hourly services provided by appellant were uniform to AEs and third parties, rejection of CUP method was unwarranted.

Annual Lettable Value of vacant property held as stock-in-trade is computed at NIL

October 30, 2023 2775 Views 0 comment Print

ITAT Kolkata held that as per provisions of section 23(1)(c) the annual lettable value of the vacant property of unsold units/flats held as stock-in-trade by the assessee but remained vacant during the year is to be computed at Rs. NIL.

Arm’s Length Price of Employee Stock Option Plan cannot be taken as NIL

October 20, 2023 1209 Views 0 comment Print

ITAT Mumbai held that Arm’s Length Price (ALP) of Employee Stock Option Plan (ESOP) cannot be taken as NIL. Accordingly, matter set aside with direction to re-compute ALP and transfer pricing adjustment.

Amount for use of transponder of telecommunication service charges doesn’t qualify as royalty

October 19, 2023 1266 Views 0 comment Print

Held that the amounts received for the use of transponder of tele-communication service charges are not royalty under section 9(1)(vi) of the Income Tax Act and also under Article 12(8) of Indo Netherland DTAA.

Receipts taxable under FTS/FIS on failure to prove basis of cost allocation

October 16, 2023 1200 Views 0 comment Print

ITAT Mumbai held that receipts taxable under Fees for Technical/ Included Services (FTS/FIS) as assessee failed to prove that it is actual reimbursement as there is no basis of allocation or actual cost incurred for affiliates.

Confirmation of addition by CIT(A) in absence of any evidence u/s 69A justified

October 14, 2023 1764 Views 0 comment Print

ITAT Raipur held that confirmation of addition under section 69A of the Income Tax Act towards unexplained money by CIT(A) in absence of any evidence justified as assessee adopted lackadaisical approach and evaded from participating in proceedings before CIT(A).

RPM is most appropriate for Benchmarking Imported Men’s Wear Resale Transactions

October 12, 2023 504 Views 0 comment Print

ITAT Mumbai held that Retail Sale Price Method (RPM) is the most appropriate method for benchmarking the international transaction of ‘import of men’s wear for resale’ between Celio Future Fashion Pvt. Ltd. and its associated enterprises.

TP adjustment deleted as ALP of ESOP expenses cannot be taken as NIL

October 11, 2023 1884 Views 0 comment Print

ITAT Mumbai held that TP adjustment in respect of international transaction of reimbursement of Employee Stock Option Plan (ESOP) Expenses deleted as Arm’s Length Price (ALP) of ESOP expenses cannot be taken as NIL.

Penalty u/s 270A unsustainable as non-declaration cannot be equated as underreporting of income

October 11, 2023 2751 Views 0 comment Print

ITAT Mumbai held that penalty under section 270A of the Income Tax Act unsustainable as non-declaration of interest on income tax refund was bona fide and cannot be said to be underreporting of income.

TP Adjustment for AMP Expenditure deleted due to Lack of Brand Promotion Agreement with AE

October 9, 2023 549 Views 0 comment Print

ITAT Mumbai held that there was no express arrangement / agreement between the assessee and the AE for incurring advertisement, marketing and promotional expenses (AMP) to promote the brand of the AE and hence the said transactions would not constitute international transaction relating to AMP expenditure. Thus, TP adjustment deleted.

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