KARNATAKA CO-OPERATIVE OIL SEEDS GROWERS FEDERATION LIMITED,BANGALORE vs. ACIT, CIRCLE 1(1)(1), BANGALORE, BMTC BUILDING, KORAMANGALA
What were the facts?
The assessee claimed deductions under Section 80P(2)(d) for interest income and Section 80M for dividend income. The Assessing Officer disallowed these deductions, and subsequently, a penalty under Section 270A was levied for misreporting income. The assessee argued these were inadvertent errors by their consultant and they had voluntarily paid the tax and interest.
What did the Tribunal hold?
The Tribunal held that the payment of tax and interest was not voluntary but a consequence of the assessment order and penalty proceedings. Since the under-reporting of income was due to misreporting, the penalty under Section 270A at 200% was mandatory and upheld.
What were the issues?
Whether the penalty under Section 270A for misreporting of income is mandatory even if the assessee claims the errors were inadvertent and voluntarily paid the tax and interest.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE
Before: SHRI WASEEM AHMED & SHRI SANDEEP SINGH KARHAIL
PER SANDEEP SINGH KARHAIL, JUDICIAL MEMBER:
The assessee has filed the present appeal against the impugned order dated 11.07.2025, passed under section 250 of the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of Income Tax Appeals, National Faceless Appeal Centre, Delhi [“learned CIT(A)”], which in turn arose from the
The order continues below.
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