“under-reporting of income”

PenaltySection 270ASection 270A402 judgments

SHARP GARUDA FARM EQUIPMENTS PVT.LTD,COIMBATORE vs. DCIT, CORPORATE CIRCLE 1, , COIMBATORE

In the result, the appeal filed by the assessee is allowed

ITA 3394/CHNY/2025[2020-21]Status: DisposedITAT Chennai17 Mar 2026AY 2020-21

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri T.N. Seetharaman, AdvocateFor Respondent: Ms. T.Mythili, JCIT

Section 143(2)Section 143(3)Section 250Section 270Section 270ASection 270A(8)Section 274Section 37

r.w.s. 144B of the Act. 4. In the assessment so completed, the AO initiated penalty proceedings u/s. 270A of the Act for under-reporting of income in consequence of misreporting. In response to the penalty notice issued u/s.274 r.w.s. 270A of the Act, the assessee filed its reply dated

VEERA REDDY POSHAM,NALGONDA vs. ACIT, CENTRAL CIRCLE1(1), HYDERABAD

In the result, ITA.No.1830/Hyd

ITA 1830/HYD/2025[2022-23]Status: DisposedITAT Hyderabad13 Mar 2026AY 2022-23

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.Nos.1829 & 1830/Hyd/2025 Assessment Years 2020-2021 & 2022-2023 Veera Reddy Posham, The Acit, Nalgonda – 508 246 Central Circle-1(1), Vs. Telangana. Hyderabad. Telangana. Pan Aijpp0376P (Applicant) (Respondent) -None- िनधा"रती "ारा/Assessee By : राज" व "ारा/Revenue By : Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 09.03.2026 घोषणा की तारीख/Pronouncement: 13.03.2026 आदेश/Order Per Vijay Pal Rao:

For Respondent: Dr. Sachin Kumar, Sr. AR

Section 10Section 132Section 143(3)Section 147Section 148Section 234FSection 250(6)Section 270ASection 80CSection 80C(2)(xvii)

u/ss 234A, 234B, 234C and fee u/s 234F is consequential and without proper computation.  The initiation of penalty proceedings u/s 270A for alleged under-reporting of income is unwarranted and unsustainable once the additions themselves are deleted. 5 ITA.Nos.1829 & 1830/Hyd./2025 General Ground The Appellant craves leave

VEERA REDDY POSHAM,NALGONDA vs. ACIT, CENTRAL CIRCLE-1(1), HYDERABAD

In the result, ITA.No.1830/Hyd

ITA 1829/HYD/2025[2020-21]Status: DisposedITAT Hyderabad13 Mar 2026AY 2020-21

For Appellant: -None-For Respondent: Dr. Sachin Kumar, Sr. AR

Section 10Section 132Section 143(3)Section 147Section 148Section 250(6)Section 270ASection 80CSection 80C(2)(xvii)

{ "clean_text": "आयकर अपीलीय अधिकरण, हैदराबाद पीठ\nIN THE INCOME TAX APPELLATE TRIBUNAL\nHyderabad ‘B’ Bench, Hyderabad\nBEFORE SHRI VIJAY

RAJKAMAL AGNIHOTRI,DEHRADUN vs. INCOME TAX OFFICER , DEHRADUN

In the result, the appeal of the assessee is allowed

ITA 240/DDN/2025[2022-23]Status: DisposedITAT Dehradun12 Mar 2026AY 2022-23

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2022-23] Rajkamal Agnihotri Vs Ito Shivalik View, Lane No.3, Ward-1(1)(3) Jogiala, Ring Road, Dehradun Nathanpur, Dehradun Uttarakhand Uttarakhand -248005 Pan-Amqpa2608G Appellant Respondent Appellant By Shri K. K. Juneja, Adv. Respondent By Ms. Poonam Sharma, Cit Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 06.11.2025 By Ld. Commissioner Of Income Tax (A), Nfac, Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2021-22/10408670 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 14.03.2024 Passed U/S 143(3) R.W.S. 144B Of The Act Pertaining To Assessment Year 2022-23. 2. Brief Facts Of The Case Are That Assessee Is An Individual & Filed His Return Of Income On 28.07.2022, Declaring Total Income Of Inr 4,89,260/-. The Return Was Updated On 11.09.2023 U/S 139(8A) Of The Act, Declaring Total Income Of Inr 73,92,200/- & Paid The Taxes Alongwith The Interest Thereon. The Case Of The Assessee Was Selected For Scrutiny On The Ground That No Capital Gain Was Reported In Itr Though The Assessee Has Sold The Property Thereafter, The Assessment Was Completed U/S 143(3)/144B Of The Act Dated 14.03.2024 Wherein Income Declared In The Updated Return Filed U/S 139(8A) Of The Act Was Accepted However, Penalty Proceedings U/S 270A(1) R.W.S. 270A(8) & 270A(9)(A) Of The Act Were Initiated. The Ao Thereafter, Proceeded With Pending Penalty Proceedings & Imposed The Penalty In Terms Of The Order Dated 14.03.2024 Imposing The Penalty Of Inr 31,58,542/- U/S 270A Of The Act.

Section 139Section 143(2)Section 143(3)Section 19Section 250Section 270Section 270ASection 270A(1)Section 9

addition-While initiating the penalty proceedings in the assessment order, the AO has not specified as to whether the penalty is initiated for "under-reporting of income" under s. 270A(2) of for "misreporting of income" under s. 270A(9)-This assumes significance because the nature, scope, and rate

SAWASTIKA PRINTING & PACKAGING,KALA MAB vs. ASSESSING OFFICER, NAHAN

In the result, appeal of the Assessee is allowed for statistical purposes

ITA 1222/CHANDI/2025[2017-2018]Status: DisposedITAT Chandigarh09 Mar 2026AY 2017-2018

Bench: the Hon'ble CIT(A)(NFAC) that assessee is having business turnover of Rs 16,77,30,943/-. While upholding the additions of Rs 20,81,000/- the Hon'ble CIT(A) (NFAC) has observed in last para of his order as under:-

For Appellant: Shri Yad Ram Saini, Advocate and Shri Neeraj Jain, C.AFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR (Virtual Mode)

Section 132Section 139(4)Section 144Section 147

under section 115BBE, resulting in an assessed income of Rs.84,54,770/-. Penalty proceedings under sections 270A and 271B were also initiated for under-reporting of income and delay in filing the tax audit report. 4. Against the order of the AO the assessee went in appeal before

THE INSTITUTE OF THE FRANCISCAN MISSIONARIES OF MARY SOCIETY NO.14 (AOP),NILGIRIS vs. ITO, EXEMTIONS,, COIMBATORE

The appeal of the assessee is allowed

ITA 3660/CHNY/2025[2017-18]Status: DisposedITAT Chennai27 Feb 2026AY 2017-18

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3660/Chny/2025 िनधा$रण वष$ /Assessment Year: 2017-18

For Appellant: Mr. Abhishek Murali, C.A ()For Respondent: Dr. M.D.Vijay Kumar, JCIT

Section 10Section 12ASection 250Section 270ASection 274

defend against levy of penalty. A perusal of the impugned notice (infra) doesn't reveal whether the AO has initiated penalty for under-reporting of income as per sub-section (1) to (7) of section 270A of the Act or misreporting of income as per section

DINESH VERMA,MANALI, HIMACHAL PRADESH vs. ITO, ITO WARD KULLU

In the result, appeal filed by the Assessee is dismissed

ITA 897/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh24 Feb 2026AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Vinamar Gupta, C.A (Virtually)For Respondent: Shri Manav Bansal, CIT, DR

Section 147Section 148Section 151ASection 263Section 270A

fresh assessment. Section 270A The Assessing Officer may, during the course of any proceedings under this Act, direct that a person who has under-reported his income shall be liable to pay a penalty. Further, under-reporting includes a case where income is assessed in a return filed ... original return and filed the return only after the issuance of notice under section 148. Therefore, the case squarely falls within the statutory under-reporting of income under section 270A.The language of section 270A clearly provides that the penalty is to be considered during the course of proceedings under

GOLDMAN SACHS SERVICES PRIVATE LIMITED,BANGALORE vs. DCIT, CIRCLE 3(1)(1), BANGALORE

ITA 2525/BANG/2024[AY 2021-22]Status: DisposedITAT Bangalore23 Feb 2026

Bench: MS. PADMAVATHY S., ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Madhur AgarwalFor Respondent: Dr. Divya K. J

Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 234ASection 270ASection 92C

case and in law, the learned AO has erred in proposing to initiate penalty proceedings under section 270A of the Act for under-reporting of income. 3. Ground No. 3: Incorrect levy of interest under section 234A, 234B and 234C of the Act The learned AO, erred

RAMANI MATHURAPRASAD MISHRA,MUMBAI vs. ITO WARD 22(3)(6), MUMBAI

ITA 7543/MUM/2025[2017-18]Status: DisposedITAT Mumbai20 Feb 2026AY 2017-18

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

For Appellant: Shri Naimish JoshiFor Respondent: Date

Section 143(1)(a)Section 144Section 144BSection 147Section 56(2)(vii)

INR.53,90,000/- disallowed on account of unexplained purchase of the property. (d) INR.4,04,998/- added due to the under-reporting of income on account of a mismatch in turnover reported in the service tax return and income tax return. (e) INR.2,95,059/- disallowed of various business expenses

MESSE FRANKFURT TRADE FAIRS INDIA PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX 2(2)(1), INCOME TAX DEPARTMENT, MUMBAI, MUMBAI

ITA 6680/MUM/2025[2018-2019]Status: DisposedITAT Mumbai19 Feb 2026AY 2018-2019

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 6498/Mum/2025 (Assessment Year: 2018-19) & 2. Ita No. 6680/Mum/2025 (Assessment Year: 2018-19) Messe Frankfurt Trade Dcit – 2(2)(1), Fairs India Private Income Tax Limited, Vs. Department, 501, 5Th Floor, Gala Mumbai-400 020 Impecca, Mumbai, Chakala Midc S.O, Mumbai-400 093. Pan/Gir No. Aabcm0696G (Applicant) (Respondent) Assessee By Shri Ninad Patade, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 18.02.2026 Date Of Pronouncement 19.02.2026

Section 143(3)Section 250Section 253(5)Section 270ASection 80G

levied under section 270A vide order dated 15.03.2024 has been confirmed. The penalty has been levied under section 270A on the allegation of under-reporting of income in consequence of misreporting thereof within the meaning of section 270A(9), in respect of the addition of Rs. 9,90,000/- sustained ... order is bad in law and liable to be quashed, as it fails to satisfy the mandatory requirement of establishing either misreporting or under-reporting of income attributable to any deliberate act or omission on the part of the Appellant company. All the above grounds are without prejudice to each

MESSE FRANKFURT TRADE FAIRS INDIA PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX 2(2)(1), MUMBAI

ITA 6498/MUM/2025[2018-2019]Status: DisposedITAT Mumbai19 Feb 2026AY 2018-2019

Section 143(3)Section 250Section 253(5)Section 270ASection 80G

ASHUTOSH DUBEY,KANJURMARG vs. DCIT CIRCLE-8, PUNE

In the result, the appeal filed by the assessee is allowed

ITA 2215/PUN/2025[2019-20]Status: DisposedITAT Pune18 Feb 2026AY 2019-20

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2215/Pun/2025 निर्धारण वषा / Assessment Year: 2019-20 Ashutosh Dubey, V Income Tax Officer, Tower 8, Flat No.3201, Runwal S Circle-8, Pune. Forest, Lbs Road, Kanjurmarg West, Maharashtra – 400078 Pan: Ajppd0173M Appellant/ Assessee Respondent /Revenue Assessee By Shri Amar Pandey (Virtual) Revenue By Smt Neha Thakur (Virtual) Date Of Hearing 20/01/2026 Date Of Pronouncement 18/02/2026

Section 139Section 139(1)Section 147Section 148Section 246ASection 250Section 270ASection 274(2)Section 5

assessee with regard to non-filing of return of income appears to be bona fide and genuine without any intention of under-reporting of income, arising on account of transfer of property in pursuant to the Joint Development Agreement. Since the assessee has already paid a substantial amount

GOLDMAN SACHS MAURITIUS NBFC LLC,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX – (INTERNATIONAL TAXATION) - 2(3)(2), MUMBAI

In the result, appeal of the assessee is allowed

ITA 5926/MUM/2025[2023-24]Status: DisposedITAT Mumbai17 Feb 2026AY 2023-24

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2023-24 Goldman Sachs Mauritius Nbfc Assistant Commissioner Of Llc, Income Tax – (International C/O Ernst & Young Llp, 14Th Taxation)-2(3)(2), Floor, The Ruby, 29 Senapati Room No.610, 6Th Floor Vs. Bapat Marg, Dadar West, Kautilya Bhavan, C-41 To C- Mumbai-400028 43, G Block, Bandra Kurla Complex, Bandra (East), Mumbai-400051 (Pan: Aaecg8689C) (Appellant) (Respondent) Present For: Assessee : Shri Hiten Thakkar, Advocate Revenue : Shri Krishna Kumar, Sr. Dr Date Of Hearing : 20.11.2025 Date Of Pronouncement : 17.02.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Final Assessment Order Passed By The Assessing Officer U/S.143(3) R.W.S. 144C(13) Of The Act Dated 14.07.2025, Pursuant To The Direction Issued By The Ld. Dispute Resolution Panel – 1, Mumbai Vide Order No. Itba/Drp/F/144C(5)/2025-26/1077165542(1), Dated 18.06.2025 Passed U/S. 144C(5) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), For Ay 2023-24. 2. Grounds Taken By The Assessee Are Reproduced As Under:

For Appellant: Shri Hiten Thakkar, AdvocateFor Respondent: Shri Krishna Kumar, Sr. DR

Section 143(3)Section 144C(5)Section 270ASection 5Section 74

circumstances of the case and in law, the learned AO erred in initiating penalty proceedings under section 270A of the Act for under-reporting of income for the AY 2023-24. 2.1 All the grounds including sub-grounds relate to one single issue in respect of setting off short term

NARROTAM MORARJEE INSTITUTE OF SHIPPING,MUMBAI vs. ITO (EXEMPTION)WARD 2(1), MUMBAI

In the result, appeal of the assessee is allowed

ITA 5559/MUM/2025[2018-19]Status: DisposedITAT Mumbai16 Feb 2026AY 2018-19

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2018-19 Narrotam Morarjee Institute Of National Faceless Shipping, Mumbai Assessment Appeal Centre 76 – Jolly Maker, Chambers – 2, (Nfac) Office Of The Vs. Vivek Shah, Mumbai, Nariman Commissioner Of Income Point S.O.-400021 Tax, Appeal, Addl/Jcit(A) Delhi (Pan : Aaatn0042R) (Appellant) (Respondent) Present For: Assessee : Shri Nishit Gandhi, Advocate Revenue : Shri Leyaqat Ali Afaqui, Sr. Dr Date Of Hearing : 18.11.2025 Date Of Pronouncement : 16.02.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Commissioner Of Income Tax (Appeal), National Faceless Appeal Centre (Nfac), Delhi Vide Order No. Itba/Nfac/S/250/2025- 26/1078465227(1) Dated 14.07.2025 Passed Against The Penalty Order U/S. 270A Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), For Ay 2018-19. 2. Grounds Taken By The Assessee Are Reproduced As Under: 1. In The Facts & Circumstances Of The Case & In Law, The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeals Centre, Delhi ["The Cit (A)") U/S 250 Of The Income Tax Act, 1961 ["The Act For Short Erred In Confirming The Penalty U/S 270A Of The Act Passed

For Appellant: Shri Nishit Gandhi, AdvocateFor Respondent: Shri Leyaqat Ali Afaqui, Sr. DR

Section 11Section 11(1)(a)Section 11(2)Section 12ASection 250Section 270A

year under consideration. He thus, added the entire amount while making the assessment. In this regard penalty proceedings u/s 270A were initiated for under-reporting of income. 4 Narottam Morarjee Institute of Shipping AY 2018-19 3.2. In the course of assessment proceeding, ld. AO also noted that assessee ... depreciation is not allowable and thus, held it to be disallowed. In this regard also, penalty proceedings u/s 270A were initiated for under-reporting of income. Assessment was thus, completed u/s 143(3) with total income assessed at Rs.81,64,360/- which is nothing but unutilized accumulation

DATAR KULMANDAL,PUNE vs. INCOME TAX OFFICER (EXEMPTION), WARD -1, PUNE

In the result, appeal of the assessee is allowed for statistical purpose

ITA 3239/PUN/2025[2022-23]Status: DisposedITAT Pune12 Feb 2026AY 2022-23

Bench: DR.DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

Section 11Section 12ASection 12A(1)Section 143(3)Section 250Section 270A

income of the year and is added to the total income of the year. Penalty proceedings u/s 270A of the IT Act for under-reporting of income is also initiated separately for under reporting of income.” 4. Being aggrieved with the above assessment order, Assessee filed an appeal before

SANTHOSH ABRAHAM,CHENNAI vs. ITO, WARD-1,, KANCHEEPURAM

In the result, the appeal filed by the assessee is allowed and the stay application filed by the assessee is dismissed

ITA 3950/CHNY/2025[2020-21]Status: DisposedITAT Chennai12 Feb 2026AY 2020-21

Bench: Shri George George K & Shri Inturi Rama Raoआयकर अपील सं./Ita No.: 3950/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 & S.A. No. 137/Chny/2025 [In Ita No. 3950/Chny/2025] Shri Santhosh Abraham, The Income Tax Officer, 21, Morrison 2Nd Street, Vs. Ward 1, Alandur, Chennai – 600 016. Kancheepuram. Pan: Aijpa 0742L (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri N.Sai Sathiyabama, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 11.02.2026 घोषणा क" तारीख/Date Of Pronouncement : 12.02.2026

For Appellant: Shri N.Sai Sathiyabama, AdvocateFor Respondent: Ms. Gouthami Manivasagam

Section 139Section 147Section 148Section 250Section 270Section 270ASection 274

vide order dated 15.01.2025. 4. Subsequent to completion of assessment, penalty notice u/s.274 r.w.s.270A of the Act was issued for under-reporting of income. During the course of penalty proceedings, it was ITA No.3950/Chny/2025& :- 3 -: SA No.137/Chny/2025 contended that assessee could not file his return of income since ... income and interest payment u/s.234A of the Act. Section 270A(6)(a) of the Act states that for the purpose of this section under-reporting of income shall not include amount of income in respect of which assessee offers an explanation which is bonafide and assessee has disclosed all material

M/S. CITADINES OMR APARTHOTEL PRIVATE LIMITED,CHENNAI vs. ITO CORP WARD 1(3), CHENNAI

In the result, the appeal of the assessee is allowed and the stay application of the assessee is dismissed as infructuous

ITA 303/CHNY/2026[2018-19]Status: DisposedITAT Chennai10 Feb 2026AY 2018-19

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.303/Chny/2026 & Sa No.29/Chny/2026 (Arising Out Of Ita No.303/Chny/2026) िनधा$रण वष$ /Assessment Year: 2018-19 M/S. Citadines Omr Aparthotel Pvt. The Income Tax Officer, Ltd., Vs. Corporate Ward-1(3), No.94, Somerset Greenways, Chennai. Sathyadev Avenue, Raja Annamalaipuram, Chennai – 600 028. Pan: Aadcr 5653C

For Respondent: Ms. R. Anitha, Addl. CIT

Section 143(3)Section 250Section 263Section 270ASection 270A(6)(a)Section 40A(7)

overall facts in this case, we are of the view that no penalty ought to have been levied u/s.270A of the Act for under-reporting of income and therefore, we direct deletion of the same.” 8. Since in the facts of the assessee's case are identical

REPRO INDIA LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, MUMBAI

The appeal is allowed for statistical purposes

ITA 7605/MUM/2025[2022-23]Status: DisposedITAT Mumbai09 Feb 2026AY 2022-23

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarrepro India Limited Acit Circle 11Th Floor, B Wing, Sun 8(1)(1), Paradise Business Plaza, Vs. Aayakar Bhavan, Senapati Bapat Marg, Mumbai-400 020 Lower Parel, Mumbai – 400 013 Pan/Gir No. Aaacr0379J (Applicant) (Respondent) Assessee By Shri Vijay Mehta, Ld. Ar Revenue By Shri Umashankar Prasad, Ld. Dr Date Of Hearing 04.02.2026 Date Of Pronouncement 09.02.2026

Section 143(3)Section 144BSection 250

effective addition of Rs. 42,54,62,348/- was worked out. Penalty proceedings under section 270A of the Act were initiated for alleged under-reporting of income. The assessment was completed under section 143(3) read with section 144B of the Act, determining total loss

KAMAL SHADIJA,INDORE vs. ASSESSMENT UNIT, INCOME TAX EPARTMENT, DELHI

Appeal is dismissed

ITA 637/IND/2025[2020-21]Status: DisposedITAT Indore06 Feb 2026AY 2020-21

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year: 2020-21 Kamal Shadija Assessment Unit 156, Palsikar Colony, Income Tax Department बनाम/ Indore Vs. (Assessee/Appellant) (Revenue/Respondent) Pan:Azsps4490H Assessee By Shri S.S. Deshpande, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 19.01.2026 Date Of Pronouncement 06.02.2026

Section 143(2)Section 270ASection 57

made by AO. (ii) In the assessment-order passed as above, the AO also initiated proceeding for imposition of penalty u/s 270A for under-reporting of income. Simultaneously, the AO also issued show-cause notice to assessee seeking an explanation as to why the penalty should not be imposed ... revenue diminution for the exchequer. The appellant's obligation is unequivocal: they cannot manipulate the circumstances to diminish their tax liability through the under-reporting of income. In light of the aforementioned legal principles and the intricacies of this case, the grounds of appeal No. 1 to 4 are dismissed

ADITYA BIRLA SUN LIFE AMC LIMITED,MAHARASHTRA vs. THE DEPUTY COMMISSIONER OF INCOME TAX- CIRCLE 6(1)(1), MAHARASHTRA

ITA 6703/MUM/2025[2023-24]Status: DisposedITAT Mumbai06 Feb 2026AY 2023-24

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar1. Ita No. 6663/Mum/2025 (Assessment Year: 2017-18) 2. Ita No. 6701/Mum/2025 (Assessment Year: 2018-19) 3. Ita No. 6702/Mum/2025 (Assessment Year: 2022-23) & 4. Ita No. 6703/Mum/2025 (Assessment Year: 2023-24) Aditya Birla Sun Life Dcitcircle-6(1)(1), Amc Limited, Room No. 502, 5Th 17Th Floor, One World Vs. Floor, Aayakar Centre Tower-1, Jupiter Bhavan, M. K. Mill Compount, 841, Road, Churchgate, Senapati Bapat Marg, Mumbai-400 020 Delisle Road, S.O. Mumbai-400 013 Pan/Gir No. Aaacb6134D (Applicant) (Respondent) Assessee By Shri Ronak Doshi, Shri Shrey Agrawal & Shri Aadish Jain, Ld. Ars Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 27.01.2026 Date Of Pronouncement 06.02.2026

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 250Section 270ASection 36(1)(va)Section 40Section 43B

that unless the error had been identified by the computerized system, it would have gone unchecked. He treated the case as one of under-reporting of income. Accordingly, the Assessing Officer made an addition of Rs. 13,46,813/- as short- term capital gains taxable under section 111A ... initiated penalty proceedings for under-reporting of income under section 270A of the Act. 90. Before the ld. CIT(A), the assessee assailed the impugned addition by filing detailed written submissions. It was contended that during the relevant previous year, the assessee had sold a total

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