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“under-reporting of income”

PenaltySection 270ASection 270A402 judgments

The decision most relied on for under-reporting of income is CIT v. Surendra Prasad Agrawal (275 ITR 113), cited in 38 judgments on BharatTax.

Leading authorities on under-reporting of income

CIT v. Surendra Prasad Agrawal
275 ITR 113 · 2005 · High Court
38
citing judgments

The omission by an Income Tax Officer to initiate penalty proceedings during the assessment, when there is an observation of under-reporting or mis-reporting of income, renders the assessment order erroneous and prejudicial to the interests of the Revenue, granting the Commissioner jurisdiction to revise such an order under Section 263.

Schneider Electric South East Asia (HQ) PTE Ltd. v. Commissioner of Income Tax (International Taxation) & Ors.
443 ITR 186 · 2022 · High Court
29
citing judgments

Penalty under Section 270A of the Income Tax Act, 1961, cannot be imposed if the Assessing Officer fails to specify which clause under Section 270A(9) applies and fails to show cause to the assessee accordingly. Strict adherence to the conditions of Section 270A is mandatory for its applicability.

Alrameez Construction (P.) Ltd. v. NFAC
152 Taxmann.com 382 · 2023 · ITAT
14
citing judgments

Penalty under Section 270A for under-reporting or mis-reporting of income cannot be sustained if additions are made under Section 56(2)(x) and the penalty notice fails to specify the limb under which proceedings are initiated.

Company Limited 432 ITR 84 (Del); 4. Schneider Electric South East Asia (HQ) Pte. Ltd. v. ACIT
145 Taxmann.com 665 · 2022 · High Court
13
citing judgments

Immunity from penalty under Section 270AA may be granted if the assessment order is silent on how the ingredients of Section 270A(9) are satisfied, and the penalty notice fails to specify whether the penalty is for 'under-reporting' or 'misreporting' of income.

GR Infraprojects Ltd. v. ACIT
158 Taxmann.com 80 · 2024 · High Court
11
citing judgments

Penalty under section 270A cannot be sustained without the Assessing Officer specifying the exact charge against the assessee, including which part of section 270A(9) is attracted. Immunity under section 270AA may be granted if the Assessing Officer fails to specify the relevant sub-clause of section 270A(9) or mechanically passes an order without considering the assessee's replies.

DCIT v. Chakradhar Contractors and Engineers (P.) Ltd.
171 Taxmann.com 133 · 2025 · Reported
10
citing judgments

Penalty under section 270A is not leviable in the absence of specifying the sub-clause of section 270A(9) under which the penalty is initiated.

Judgments citing under-reporting of income

Cil Employees Co Op Credit Society Limited, Pune vs. Exemption, Ward-1(2), Pune

In the result, appeal filed by the Assessee is allowed for statistical purpose

ITA 1600/PUN/2025[2020-21]Status: DisposedITAT Pune19 Jan 2026AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1600/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Cil Employees’ Co Op Credit V Exemption, Society Limited, S Ward-1(2), Pune. Cummins Inida Ltd., Kothrud, Pune – 411038. Pan:Aabac8908M Appellant / Assessee Respondent / Revenue Assessee By Shri Kishore Phadke Revenue By Shri Sandeep Sathe – Jcit Date Of Hearing 08/12/2025 Date Of Pronouncement 19/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2020-21 Dated 29.02.2024 Emanating From The Assessment Order Passed Under Section 143(3) Read With Section 144B Of The I.T .Act, 1961 Dated 28.09.2022. The Assessee Has Raised The Following Grounds Of Appeal :

Section 143(1)Section 143(3)Section 144BSection 250Section 80PSection 80P(2)(a)Section 80P(2)(b)Section 80P(2)(d)Section 80P(4)

appellant is enhanced to Rs.1,78,37,072/- in place of income determined by the AO at Rs.4,77,420/-. For the above under-reporting of income, penalty proceedings u/s 270A(1)(2)(a) of the Income tax Act, 1961.” ITA No.1600/PUN/2025 [A] 2.3 In this case, thus, ld.CIT

DCIT-3(1)(1), Mumbai vs. Relcon Infraprojects Ltd., Mumbai

ITA 7070/MUM/2025[2020-21]Status: DisposedITAT Mumbai19 Jan 2026AY 2020-21

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ravikant PathakFor Respondent: Shri Annavaran Kosuri
Section 132Section 143(3)Section 153ASection 270ASection 271(1)(c)Section 68

18/01/2022 and 10/11/2023 issued under Section 274 read with 270A of the Act, the Assessing Officer confronted the Assessee with the charge of under-reporting of income in consequence of misreporting. It reply it was contended by the Assessee that the Assessee Clause (a) to (e) of Section 270A ... case the Assessment Year 2014-2015 to 2019-2020 claim for deduction for purchase expenses was ‘not substantiated by any evidence’. Therefore, the under-reporting of income by the Assessee cannot be regarded as under-reporting in consequence of misreporting falling within the ambit of Section 270A

DCIT-3(1)(1), Mumbai vs. Relcon Infraprojects Ltd., Mumbai

ITA 7069/MUM/2025[2019-20]Status: DisposedITAT Mumbai19 Jan 2026AY 2019-20

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ravikant PathakFor Respondent: Shri Annavaran Kosuri
Section 132Section 143(3)Section 153ASection 270ASection 271(1)(c)Section 68

18/01/2022 and 10/11/2023 issued under Section 274 read with 270A of the Act, the Assessing Officer confronted the Assessee with the charge of under-reporting of income in consequence of misreporting. It reply it was contended by the Assessee that the Assessee Clause (a) to (e) of Section 270A ... case the Assessment Year 2014-2015 to 2019-2020 claim for deduction for purchase expenses was ‘not substantiated by any evidence’. Therefore, the under-reporting of income by the Assessee cannot be regarded as under-reporting in consequence of misreporting falling within the ambit of Section 270A

DCIT-3(1)(1), Mumbai vs. Relcon Infraprojects Ltd., Mumbai

ITA 7068/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ravikant PathakFor Respondent: Shri Annavaran Kosuri
Section 132Section 143(3)Section 153ASection 270ASection 271(1)(c)Section 68

18/01/2022 and 10/11/2023 issued under Section 274 read with 270A of the Act, the Assessing Officer confronted the Assessee with the charge of under-reporting of income in consequence of misreporting. It reply it was contended by the Assessee that the Assessee Clause (a) to (e) of Section 270A ... case the Assessment Year 2014-2015 to 2019-2020 claim for deduction for purchase expenses was ‘not substantiated by any evidence’. Therefore, the under-reporting of income by the Assessee cannot be regarded as under-reporting in consequence of misreporting falling within the ambit of Section 270A

DCIT-3(1)(1), Mumbai vs. Relcon Infraprojects Ltd., Mumbai

ITA 7067/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Jan 2026AY 2017-18

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ravikant PathakFor Respondent: Shri Annavaran Kosuri
Section 132Section 143(3)Section 153ASection 270ASection 271(1)(c)Section 68

18/01/2022 and 10/11/2023 issued under Section 274 read with 270A of the Act, the Assessing Officer confronted the Assessee with the charge of under-reporting of income in consequence of misreporting. It reply it was contended by the Assessee that the Assessee Clause (a) to (e) of Section 270A ... case the Assessment Year 2014-2015 to 2019-2020 claim for deduction for purchase expenses was ‘not substantiated by any evidence’. Therefore, the under-reporting of income by the Assessee cannot be regarded as under-reporting in consequence of misreporting falling within the ambit of Section 270A

DCIT-3(1)(1), Mumbai vs. Relcon Infraprojects Ltd., Mumbai

ITA 7066/MUM/2025[2016-17]Status: DisposedITAT Mumbai19 Jan 2026AY 2016-17

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ravikant PathakFor Respondent: Shri Annavaran Kosuri
Section 132Section 143(3)Section 153ASection 270ASection 271(1)(c)Section 68

18/01/2022 and 10/11/2023 issued under Section 274 read with 270A of the Act, the Assessing Officer confronted the Assessee with the charge of under-reporting of income in consequence of misreporting. It reply it was contended by the Assessee that the Assessee Clause (a) to (e) of Section 270A ... case the Assessment Year 2014-2015 to 2019-2020 claim for deduction for purchase expenses was ‘not substantiated by any evidence’. Therefore, the under-reporting of income by the Assessee cannot be regarded as under-reporting in consequence of misreporting falling within the ambit of Section 270A

DCIT 3(1)(1), Mumbai vs. Relcon Infraprojects Ltd, Mumbai

ITA 7065/MUM/2025[2015-16]Status: DisposedITAT Mumbai19 Jan 2026AY 2015-16

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ravikant PathakFor Respondent: Shri Annavaran Kosuri
Section 132Section 143(3)Section 153ASection 270ASection 271(1)(c)Section 68

18/01/2022 and 10/11/2023 issued under Section 274 read with 270A of the Act, the Assessing Officer confronted the Assessee with the charge of under-reporting of income in consequence of misreporting. It reply it was contended by the Assessee that the Assessee Clause (a) to (e) of Section 270A ... case the Assessment Year 2014-2015 to 2019-2020 claim for deduction for purchase expenses was ‘not substantiated by any evidence’. Therefore, the under-reporting of income by the Assessee cannot be regarded as under-reporting in consequence of misreporting falling within the ambit of Section 270A

DCIT-3(1)(1), Mumbai vs. Relcon Infraprojects Ltd., Mumbai

ITA 7064/MUM/2025[2014-15]Status: DisposedITAT Mumbai19 Jan 2026AY 2014-15

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ravikant PathakFor Respondent: Shri Annavaran Kosuri
Section 132Section 143(3)Section 153ASection 270ASection 271(1)(c)Section 68

18/01/2022 and 10/11/2023 issued under Section 274 read with 270A of the Act, the Assessing Officer confronted the Assessee with the charge of under-reporting of income in consequence of misreporting. It reply it was contended by the Assessee that the Assessee Clause (a) to (e) of Section 270A ... case the Assessment Year 2014-2015 to 2019-2020 claim for deduction for purchase expenses was ‘not substantiated by any evidence’. Therefore, the under-reporting of income by the Assessee cannot be regarded as under-reporting in consequence of misreporting falling within the ambit of Section 270A

Dinesh Chand Kaushik, Aligarh vs. ITO, Delhi

In the result, assessee’s appeal is allowed for statistical purposes

ITA 469/AGR/2025[2021-22]Status: DisposedITAT Agra15 Jan 2026AY 2021-22

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2021-22

Section 144Section 250Section 270ASection 41(1)

r.w.s. 144B of the Act and assessed an income of Rs.16,59,86,605/-. The penalty proceedings u/s. 270A of the Act for under-reporting of income were also initiated, based on the addition of Rs.4,04,56,421/- made u/s. 41(1) of the Act on account of unexplained

Laxmichand and Company, Gwalior vs. DCIT/ACIT 1(1), Gwl, Gwalior

In the result, assessee’s appeal is allowed

ITA 313/AGR/2025[201718]Status: DisposedITAT Agra15 Jan 2026

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2017-18

Section 143(3)Section 145(3)Section 250Section 270ASection 44A

submitted that clause (b) of section 270A(6) of the Act expressly excludes additions made on an estimated basis from the ambit of “under-reporting of income.” Therefore, no penalty under section 270A can be sustained where the addition itself is 4 | P a g e based merely on estimation ... expenses, and other related factors. Such an addition, having been made purely on an estimated basis, is specifically excluded from the ambit of “under-reporting of income” in terms of section 270A(6)(b) of the Act, if the accounts are correct and complete to the satisfaction of the Assessing

Deputy Commissioner of Income Tax, Circle-1(1), Chandigarh vs. Frontier Agrotech Private Limited, Chandigarh

ITA 388/CHANDI/2025[2022-23]Status: DisposedITAT Chandigarh14 Jan 2026AY 2022-23

Bench: The Appeal Is Heard Or Is Disposed Off.

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 143(3)Section 144B

under section 143(3) read with section 144B at a total income of Rs.168,60,19,367/-, while simultaneously initiating penalty proceedings for under-reporting of income. 4. Against the order of the AO the assessee went in appeal before the Ld. CIT(A). The Ld. CIT(A), upon

Delhi Gujarat Fleet Carriers Private Limited, Gurgaon vs. Dy. Commissioner of Income Tax, Circle-1(1), Gurgaon

In the result, the Assessee’s appeal is partly allowed

ITA 6273/DEL/2025[2021-22]Status: DisposedITAT Delhi13 Jan 2026AY 2021-22

Bench: Shri Mahavir Singh, Hon’Ble & Smt. Renu Jauhri, Hon’Bleasstt. Year : 2021-22 Delhi Gujarat Fleet Carriers Vs. Dcit, Circle 1(1), Private Limited, Aayakar Bhawan, H.No. 1/34, Shivaji Nagar, Udyog Vihar, Gurgaon Phase-V, Gurgaon (Pan: Aaccd6847K) (Appellant) (Respondent) Appellant By : Ms. Kavita Gupta, Ca Respondent By : Sh. Ajay Kumar Arora, Sr. Dr

For Appellant: Ms. Kavita Gupta, CAFor Respondent: Sh. Ajay Kumar Arora, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 144BSection 194CSection 270A

section 144B, assessing total income at Rs. 17,72,53,922/-. Further, penalty proceedings under 2 | P a g e section 270A for under-reporting of income were initiated separately. Against the action of the AO, the assessee preferred appeal before the Ld. CIT(A), who vide his impugned order

Granules India Limited, Hyderabad vs. DCIT., Circle-2(1), Hyderabad

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

ITA 1295/HYD/2025[2020-21]Status: DisposedITAT Hyderabad24 Dec 2025AY 2020-21

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं /Ita No.1295/Hyd/2025 (िनधा"रण वष"/Assessment Year:2020-21) M/S. Granules India Limited, Dy. Commissioner Of Income Vs. Hyderabad. Tax, Pan : Aaacg7369K Circle 2(1), Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Y.V. Bhanu Narayan Rao, C.A. राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr-Dr सुनवाई की तारीख/Date Of Hearing: 22/12/2025 घोषणा की तारीख/Pronouncement: 24/12/2025

For Appellant: Shri Y.V. Bhanu Narayan RaoFor Respondent: Dr. Sachin Kumar, SR-DR
Section 139(1)Section 143(1)Section 143(3)Section 154Section 155(18)Section 270A

Section 270A of the Act, dated 23/02/2023, imposed upon the assessee company, the penalty under Section 270A of Rs. 82,63,156 for under-reporting of income w.r.t the disallowance of HEC of Rs. 4,81,53,591/-. 6. Aggrieved, the assessee company assailed the penalty imposed ... these additions made, the AO initiated penalty proceedings u/s.270A of the Act and imposed penalty of Rs.82,63,156/- for under-reporting of income, as above. 5.2 The AO had noticed that in the return of income appellant had claimed Education Cess of Rs.4,81,53,591/- as admissible expenses

Nirjeet Singh, Delhi vs. ITO Ward 52(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 5151/DEL/2025[2022-23]Status: DisposedITAT Delhi23 Dec 2025AY 2022-23

Bench: Shri Vimal Kumar & Smt. Renu Jauhriassessment Year: 2022-23 Shri Nirjeet Singh Vs Ito Ward 52(1) 117, Palika Bazar New Delhi Connaught Place New Delhi- 110001 (Appellant) (Respondent) Pan No. Ablps0458C

For Appellant: Shri K. Sampath, AdvFor Respondent: Ms. Ankush Kalra, SR. DR
Section 250Section 270ASection 270A(9)Section 270A(9)(c)Section 274

benefit of immunity u/s 270AA of the Act. 4.1 Alternatively, Ld. AR has submitted that on merits also, there is no case of under-reporting of income as the transactions stand fully explained by the assessee and the case is not covered under any of the clauses of section 270A ... liable to be deleted. 5. On the other hand, Ld. DR has argued that immunity u/s 270AA is available only for under-reporting of income and not for mis-reporting. The cases of mis-reporting have been mentioned in clauses (a) to (f) of sub-section 9 of Section 270A

Harish Banga, Hisar vs. Assessment Unit, New Delhi

In the result, both the substantial ground of appeal is allowed

ITA 4893/DEL/2025[2018-19]Status: DisposedITAT Delhi19 Dec 2025AY 2018-19

Bench: Shri Pawan Singhassessment Year: 2018-19 (Physical Hearing) Harish Banga, Assessment Unit, 264, Bank Colony, Hisar, Vs. Faceless Assessment Unit Haryana – 125001. Income Tax Department, Pan – Abqpb 8845 F New Delhi-110001. (Appellant) (Respondent) Present For: Assessee By : Shri H.K. Batra, Ca & Shri Naman Chawla, Ca Revenue By : Shri Virender Kumar Singh, Sr. D.R. Date Of Hearing : 04.12.2025 Date Of Pronouncement : 19.12 .2025 O R D E R Per : Pawan Singh: This Appeal By The Assessee Is Directed Against The Order Of Cit (A) Dated 08.07.2025 Vide Assessment Year 2018-19. The Assessee Has Raised Following Grounds Of Appeal:-

For Appellant: Shri H.K. Batra, CA &For Respondent: Shri Virender Kumar Singh, SR. D.R
Section 147Section 148Section 148ASection 151ASection 56Section 57

order perverse and unsustainable. 5.1 The Ld. CIT(A) erred in not adjudicating on the initiation of penalty proceedings u/s 270A for alleged under-reporting of income, which was raised as a ground of appeal before the CIT(A). 5.2 The Ld. CIT(A) failed to appreciate that the disallowance ... expenses does not constitute under-reporting of income, as the commission income of Rs. 13,50,380/- was fully disclosed in the return of income, and the dispute pertains only to the allowability of expenses. 5.3 The initiation of penalty proceedings is premature and unjustified, as no willful concealment

Krishi Upaj Mandi Samiti, Chaapeheda vs. Neac, Delhi

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

ITA 56/IND/2025[2018-19]Status: DisposedITAT Indore17 Dec 2025AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Shri Harsh Vijaywargiya, CAFor Respondent: Shri Ashish Porwal, Sr. DR
Section 10Section 12ASection 143(1)Section 144Section 144BSection 270ASection 272A(1)(d)

assessee. The total income was thus assessed at ₹12,51,770/- and penalty proceedings under section 270A were also initiated separately for under-reporting of income. 4. Aggrieved by the assessment order, the assessee preferred an appeal before the Ld. CIT(Appeals). At the outset, the Ld. CIT(A) noted

Krishi Upaj Mandi Samiti, Chaapeheda, Chhapiheda vs. Neac, Delhi

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

ITA 55/IND/2025[2018-19]Status: DisposedITAT Indore17 Dec 2025AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Shri Harsh Vijaywargiya, CAFor Respondent: Shri Ashish Porwal, Sr. DR
Section 10Section 12ASection 143(1)Section 144Section 144BSection 270ASection 272A(1)(d)

assessee. The total income was thus assessed at ₹12,51,770/- and penalty proceedings under section 270A were also initiated separately for under-reporting of income. 4. Aggrieved by the assessment order, the assessee preferred an appeal before the Ld. CIT(Appeals). At the outset, the Ld. CIT(A) noted

Krishi Upaj Mandi Samiti, Chaapeheda vs. Neac, Delhi

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

ITA 54/IND/2025[2018-19]Status: DisposedITAT Indore17 Dec 2025AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Shri Harsh Vijaywargiya, CAFor Respondent: Shri Ashish Porwal, Sr. DR
Section 10Section 12ASection 143(1)Section 144Section 144BSection 270ASection 272A(1)(d)

assessee. The total income was thus assessed at ₹12,51,770/- and penalty proceedings under section 270A were also initiated separately for under-reporting of income. 4. Aggrieved by the assessment order, the assessee preferred an appeal before the Ld. CIT(Appeals). At the outset, the Ld. CIT(A) noted

Krishna Prabha Sundarapandy, Kanchipuram vs. DCIT, Corporate Circle-6(2), Chennai

In the result, the appeal of the assessee is allowed

ITA 2304/CHNY/2025[2022-23]Status: DisposedITAT Chennai17 Dec 2025AY 2022-23

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2304/Chny/2025 िनधा%रण वष% /Assessment Year: 2022-23

For Appellant: Mr. S. Jayakumar, AdvocateFor Respondent: Ms. Babitha, JCIT
Section 143(3)Section 250Section 270A

find that both in the assessment order as well as the order passed by learned CIT(A), the findings is only about under-reporting of income. Sub-section (1) to Section 270A of the Act provides that the Assessing Officer “may” during the course of any proceedings direct that ... person who has under-reported his income shall be liable to pay penalty in addition to tax, if any, on the under-reported income. 17. It is contended on behalf of the appellant that in Chakradhar Contractors and Engineers (P.) Ltd. (supra) a co-ordinate Bench of this Tribunal

Ca (Singapore) Pte Ltd, Mumbai vs. Assistant Commissioner of Income Tax International Taxation Circle 2(1)(1), Mumbai

In the result, the appeal of the assessee partly allowed

ITA 2078/MUM/2025[2022-23]Status: DisposedITAT Mumbai16 Dec 2025AY 2022-23

Bench: Ms Suchitra Kamble & Shri Girish Agrawalca(Singapore) Pte Ltd., The Assistant Vs. C/O Ca (India) Technologies Commissioner Of India Private Limited, Income Tax, S1 Wipro Sez, International Taxation, Doddathogur Village, Circle2 (1)(1), Begur Hobli, Mumbai. Electronic City, Bangalore-560100. [Pan :Aahcc8349Q] (Appellant) .. (Respondent) Appellant By : Shri Ajit Jain, With Shri, Siddesh Chaugule, Ars Respondent By: Shri Krishna Kumar, Sr. Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 16.12.2025 O R D E R Per Suchitra Kamble:

For Appellant: Shri Ajit Jain, with Shri, Siddesh Chaugule, ARsFor Respondent: Shri Krishna Kumar, Sr. DR
Section 142(1)Section 142(2)Section 143(2)Section 143(3)Section 195Section 270ASection 274

penalty proceedings 6.1 The Ld. AO has erred in initiating penalty proceedings u/s 270A read with section 274 of the Act alleging under-reporting of income. 7. Relief 7.1 The Appellant prays that the Ld. AO be directed to grant all such relief arising from the preceding grounds as also