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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


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

November 4, 2023 534 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 2898 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 1350 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 1401 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 1278 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 1926 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 579 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 2019 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 2850 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 648 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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