M/S. REDINGTON DISTRIBUTION PTE LTD.,SINGAPORE vs. ACIT, INTL TAXN CIRCLE-2(1), CHENNAI

ITA 1215/CHNY/2025Status: DisposedITAT Chennai26 September 2025AY 2017-18Bench: SHRI ABY T. VARKEY (Judicial Member), SHRI S.R.RAGHUNATHA (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the penalty levied under Section 270A was unjustified. The MAP resolution did not imply an admission of inaccurate reporting, and the adjustments were based on an ad-hoc estimate rather than definitive findings of concealment.

What were the facts?

The assessee, a foreign company, had income attributed to a Permanent Establishment (PE) in India. This was settled through a Mutual Agreement Procedure (MAP) under the India-Singapore DTAA, which resulted in a downward adjustment to the initial addition. The tax authorities then levied penalty for under-reporting of income.

What were the issues?

Whether penalty for under-reporting of income is leviable when the income addition was a result of a MAP settlement involving downward adjustments, and if the settlement itself implies inaccurate reporting by the assessee.

Which sections of the Income-tax Act were involved?

Section 270A,Section 271(1)(c)

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Income Tax Appellate Tribunal, ‘C’ BENCH: CHENNAI

Before: SHRI ABY T. VARKEY & SHRI S.R.RAGHUNATHA

Hearing: 14.08.2025Pronounced: 26.09.2025

PER ABY T. VARKEY, JM: These are appeals preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeals), (hereinafter referred

to as ‘Ld.CIT(A)‘), Chennai-16, dated 20.03.2025 for the Assessment Year

(hereinafter referred to as ‘AY‘) 2017-18, 2018-19 & 2020-21. 2. At the time of hearing, both the parties agreed that the issues

permeating in all the appeals are

The order continues below.

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