DEPUTY COMMISSIONER OF INCOME TAX , CHENNAI vs. SUNDARAM FINANCE LIMITED , CHENNAI

ITA 3033/CHNY/2025Status: DisposedITAT Chennai04 June 2026AY 2017-1811 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the assessee's claim was bona fide, supported by judicial precedent prevailing at the time of filing the return, and all material facts were disclosed. Therefore, the penalty under Section 270A was not exigible.

What were the facts?

The assessee, a non-banking finance company, recovered bad debts written off by amalgamating companies. The Assessing Officer (AO) brought this recovery to tax and levied penalty under Section 270A for under-reporting income. The Commissioner of Income Tax (Appeals) deleted the penalty.

What were the issues?

Whether penalty under Section 270A is leviable when the assessee's claim is based on a bona fide interpretation of law and prevailing judicial precedent, despite a subsequent contrary ruling.

Which sections of the Income-tax Act were involved?

Section 270A,Section 41(4),Section 41(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘C’ BENCH, CHENNAI

Before: SHRI S.S. VISWANETHRA RAVI & SHRI S. R. RAGHUNATHA

Hearing: 11.03.2026Pronounced: 04.06.2026

PER S. R. RAGHUNATHA, AM : This appeal by the assessee is arising out of the order dated 25.08.2025 passed by the Learned Commissioner of Income Tax (Appeal), National Faceless Appeal Centre, Delhi (in short “ld.CIT(A)”) for the assessment year (A.Y) 2017-18 against the order u/s.270A of the Income Tax Act, 1961 (hereinafter the ‘Act’) passed by the Assessment Unit (in short ‘AO’), dated 24.03

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 270A

All 4,156 judgments and leading authorities on Section 270A →

Recent GST High Court judgments

Search GST case law →