← All Phrases

“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

Chungath Varghese Sunny, Coimbatore vs. DCIT, CC-3(3), Chennai

In the result, the appeals of the assessee in ITA Nos

ITA 1806/CHNY/2025[2017-18]Status: DisposedITAT Chennai28 Oct 2025AY 2017-18

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

For Appellant: Shri. S. Sridhar, Advocate (Erode)For Respondent: Shri. Shiva Srinivas, CIT
Section 131Section 132Section 132(4)Section 143(2)Section 153CSection 270A

above, the AO initiated penalty proceedings u/s.270A of the Act by issuing a show cause notice dated 28.03.2023, proposing levy of penalty for under-reporting of income in consequence of misreporting. The AO observed that the assessee had not recorded gross profit of Rs.74,88,876/- arising from the sale ... above, the AO, vide order dated 21.09.2023, levied penalty of Rs.26,61,172/- for the A.Y.2017-18 u/s.270A(9)(e) of the Act for under-reporting of income in consequence of misreporting. 31. Aggrieved of the above penalty order, assessee preferred appeal before the ld.CIT(A) who vide order dated

Chungath Varghese Sunny, Coimbatore vs. DCIT, CC-3(3), Chennai

In the result, the appeals of the assessee in ITA Nos

ITA 1805/CHNY/2025[2021-22]Status: DisposedITAT Chennai28 Oct 2025AY 2021-22

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

For Appellant: Shri. S. Sridhar, Advocate (Erode)For Respondent: Shri. Shiva Srinivas, CIT
Section 131Section 132Section 132(4)Section 143(2)Section 153CSection 270A

above, the AO initiated penalty proceedings u/s.270A of the Act by issuing a show cause notice dated 28.03.2023, proposing levy of penalty for under-reporting of income in consequence of misreporting. The AO observed that the assessee had not recorded gross profit of Rs.74,88,876/- arising from the sale ... above, the AO, vide order dated 21.09.2023, levied penalty of Rs.26,61,172/- for the A.Y.2017-18 u/s.270A(9)(e) of the Act for under-reporting of income in consequence of misreporting. 31. Aggrieved of the above penalty order, assessee preferred appeal before the ld.CIT(A) who vide order dated

Chungath Varghese Sunny, Coimbatore vs. DCIT, CC-3(3), Chennai

In the result, the appeals of the assessee in ITA Nos

ITA 1804/CHNY/2025[2020-21]Status: DisposedITAT Chennai28 Oct 2025AY 2020-21

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

For Appellant: Shri. S. Sridhar, Advocate (Erode)For Respondent: Shri. Shiva Srinivas, CIT
Section 131Section 132Section 132(4)Section 143(2)Section 153CSection 270A

above, the AO initiated penalty proceedings u/s.270A of the Act by issuing a show cause notice dated 28.03.2023, proposing levy of penalty for under-reporting of income in consequence of misreporting. The AO observed that the assessee had not recorded gross profit of Rs.74,88,876/- arising from the sale ... above, the AO, vide order dated 21.09.2023, levied penalty of Rs.26,61,172/- for the A.Y.2017-18 u/s.270A(9)(e) of the Act for under-reporting of income in consequence of misreporting. 31. Aggrieved of the above penalty order, assessee preferred appeal before the ld.CIT(A) who vide order dated

Chungath Varghese Sunny, Coimbatore vs. DCIT, CC-3(3), Chennai

In the result, the appeals of the assessee in ITA Nos

ITA 1803/CHNY/2025[2019-20]Status: DisposedITAT Chennai28 Oct 2025AY 2019-20

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

For Appellant: Shri. S. Sridhar, Advocate (Erode)For Respondent: Shri. Shiva Srinivas, CIT
Section 131Section 132Section 132(4)Section 143(2)Section 153CSection 270A

above, the AO initiated penalty proceedings u/s.270A of the Act by issuing a show cause notice dated 28.03.2023, proposing levy of penalty for under-reporting of income in consequence of misreporting. The AO observed that the assessee had not recorded gross profit of Rs.74,88,876/- arising from the sale ... above, the AO, vide order dated 21.09.2023, levied penalty of Rs.26,61,172/- for the A.Y.2017-18 u/s.270A(9)(e) of the Act for under-reporting of income in consequence of misreporting. 31. Aggrieved of the above penalty order, assessee preferred appeal before the ld.CIT(A) who vide order dated

Chungath Varghese Sunny, Coimbatore vs. DCIT, CC-3(3), Chennai

ITA 1802/CHNY/2025[2018-19]Status: DisposedITAT Chennai28 Oct 2025AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.:1801 To 1805/Chny/2025 & 1806 To 1810/Chny/2025 निर्धारण वर्ष / Assessment Years: 2017-18 To 2021 -22 & 2017-18 To 2021-22 Chungath Varghese Sunny, 275-276, Cross Cut Road, Gandhipuram, Coimbatore – 641 012. [Pan:Ageps-1475-K] (अपीलार्थी/Appellant) Dcit, Vs. Central Circle -3(3), Chennai. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri. S. Sridhar, Advocate (Erode) प्रत्यर्थी की ओर से /Respondent By : Shri. Shiva Srinivas, Cit सुनवाई की तारीख/Date Of Hearing : 17.09.2025 घोषणा की तारीख/Date Of Pronouncement : 28.10.2025 आदेश /O R D E R Per Bench: These Ten Appeals Of The Assessee Are Directed Against The Different Orders Of The Learned Commissioner Of Income Tax (Appeals), Chennai 20 [Hereinafter Referred To As The “Id.Cit(A)”] Arising Out Of The Orders Passed By The Deputy Commissioner Of Income Tax, Central Circle – 3(3), Chennai [Hereinafter Referred To As The “Ao”], U/S.153C R.W.S 143(3)/143(3)/270A Of The Income-Tax Act, 1961 [Hereinafter Referred To As The “Act”] For The Assessment Years (“Ay/Ays”) 2017-18 To 2021-22. These Appeals Bearing Ita Nos.1801 To 1805/Chny/2025 Pertain To The Assessment Orders Passed U/S.153C R.W.S.143(3)/143(3) Of The Act, Whereas The Appeals Bearing Ita Nos.1806 To 1810/Chny/2025 Pertain To The Penalty Orders Passed U/S.270A Of The Act. 2. Since The Issues Involved In All The Five Assessment Years Under Consideration Are Identical In Nature & The Arguments Advanced By Both The Parties Are Common, All These Appeals Were Heard Together & Are Being Disposed Of By This Consolidated Order For The Sake Of Convenience & Brevity. We Shall First Address The Quantum Assessments.

For Appellant: Shri. S. Sridhar, Advocate (Erode)For Respondent: Shri. Shiva Srinivas, CIT
Section 131Section 132Section 132(4)Section 143(2)Section 153CSection 270A

above, the AO initiated penalty proceedings u/s.270A of the Act by issuing a show cause notice dated 28.03.2023, proposing levy of penalty for under-reporting of income in consequence of misreporting. The AO observed that the assessee had not recorded gross profit of Rs.74,88,876/- arising from the sale ... above, the AO, vide order dated 21.09.2023, levied penalty of Rs.26,61,172/- for the A.Y.2017-18 u/s.270A(9)(e) of the Act for under-reporting of income in consequence of misreporting. 31. Aggrieved of the above penalty order, assessee preferred appeal before the Id.CIT(A) who vide order dated

Chungath Varghese Sunny, Coimbatore vs. DCIT, CC-3(3), Chennai

In the result, the appeals of the assessee in ITA Nos

ITA 1801/CHNY/2025[2017-18]Status: DisposedITAT Chennai28 Oct 2025AY 2017-18

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

For Appellant: Shri. S. Sridhar, Advocate (Erode)For Respondent: Shri. Shiva Srinivas, CIT
Section 131Section 132Section 132(4)Section 143(2)Section 153CSection 270A

above, the AO initiated penalty proceedings u/s.270A of the Act by issuing a show cause notice dated 28.03.2023, proposing levy of penalty for under-reporting of income in consequence of misreporting. The AO observed that the assessee had not recorded gross profit of Rs.74,88,876/- arising from the sale ... above, the AO, vide order dated 21.09.2023, levied penalty of Rs.26,61,172/- for the A.Y.2017-18 u/s.270A(9)(e) of the Act for under-reporting of income in consequence of misreporting. 31. Aggrieved of the above penalty order, assessee preferred appeal before the ld.CIT(A) who vide order dated

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Tiruvannamalai

In the result, all the six appeals of the Revenue are

ITA 1655/CHNY/2025[2021-22]Status: DisposedITAT Chennai21 Oct 2025AY 2021-22

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

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

order of the CIT(A) dated 12.03.2025, wherein he deleted the penalty imposed by the AO u/s.270A of the Act on account of under-reporting of income consequent to misreporting. 45. The assessee was subjected to a search action u/s.132 of the Act on 25.03.2021. Consequent thereto, the AO issued ... seen from the above that as per subsection (2) of section 270A of the Act, a person is considered to have under-reported his income under six different situations. One among them is that the income assessed is greater than the income tax return processed under clause

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Thiruvannamalai

In the result, all the six appeals of the Revenue are

ITA 1654/CHNY/2025[2020-21]Status: DisposedITAT Chennai21 Oct 2025AY 2020-21

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

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

order of the CIT(A) dated 12.03.2025, wherein he deleted the penalty imposed by the AO u/s.270A of the Act on account of under-reporting of income consequent to misreporting. 45. The assessee was subjected to a search action u/s.132 of the Act on 25.03.2021. Consequent thereto, the AO issued ... seen from the above that as per subsection (2) of section 270A of the Act, a person is considered to have under-reported his income under six different situations. One among them is that the income assessed is greater than the income tax return processed under clause

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Thiruvannamalai

In the result, all the six appeals of the Revenue are

ITA 1653/CHNY/2025[2019-20]Status: DisposedITAT Chennai21 Oct 2025AY 2019-20

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

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

order of the CIT(A) dated 12.03.2025, wherein he deleted the penalty imposed by the AO u/s.270A of the Act on account of under-reporting of income consequent to misreporting. 45. The assessee was subjected to a search action u/s.132 of the Act on 25.03.2021. Consequent thereto, the AO issued ... seen from the above that as per subsection (2) of section 270A of the Act, a person is considered to have under-reported his income under six different situations. One among them is that the income assessed is greater than the income tax return processed under clause

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Tiruvannamalai

In the result, all the six appeals of the Revenue are

ITA 1652/CHNY/2025[2018-19]Status: DisposedITAT Chennai21 Oct 2025AY 2018-19

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

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

order of the CIT(A) dated 12.03.2025, wherein he deleted the penalty imposed by the AO u/s.270A of the Act on account of under-reporting of income consequent to misreporting. 45. The assessee was subjected to a search action u/s.132 of the Act on 25.03.2021. Consequent thereto, the AO issued ... seen from the above that as per subsection (2) of section 270A of the Act, a person is considered to have under-reported his income under six different situations. One among them is that the income assessed is greater than the income tax return processed under clause

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Tiruvannamalai

In the result, all the six appeals of the Revenue are

ITA 1651/CHNY/2025[2017-18]Status: DisposedITAT Chennai21 Oct 2025AY 2017-18

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

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

order of the CIT(A) dated 12.03.2025, wherein he deleted the penalty imposed by the AO u/s.270A of the Act on account of under-reporting of income consequent to misreporting. 45. The assessee was subjected to a search action u/s.132 of the Act on 25.03.2021. Consequent thereto, the AO issued ... seen from the above that as per subsection (2) of section 270A of the Act, a person is considered to have under-reported his income under six different situations. One among them is that the income assessed is greater than the income tax return processed under clause

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Chennai

In the result, all the six appeals of the Revenue are

ITA 1650/CHNY/2025[2015-16]Status: DisposedITAT Chennai21 Oct 2025AY 2015-16

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

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

order of the CIT(A) dated 12.03.2025, wherein he deleted the penalty imposed by the AO u/s.270A of the Act on account of under-reporting of income consequent to misreporting. 45. The assessee was subjected to a search action u/s.132 of the Act on 25.03.2021. Consequent thereto, the AO issued ... seen from the above that as per subsection (2) of section 270A of the Act, a person is considered to have under-reported his income under six different situations. One among them is that the income assessed is greater than the income tax return processed under clause

Assistant Commissioner of Income Tax, Circle-1(1), Tirupati vs. Venkata Swamy Ravuri, Chittoor

In the result, the appeal of the Revenue is allowed for

ITA 257/HYD/2022[2017-18]Status: DisposedITAT Hyderabad17 Oct 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Vice- & Shri Madhusudan Sawdia

For Appellant: Advocate Sashank Dundu
Section 143(3)Section 2Section 68

total income of the assessee and brought to tax. Additions 1: Rs.10,25,104/- \. As the above addition partakes the character of under-reporting of income, penalty is initiated u/s 270A of the I.T.Act,1961. 7.1 It is evident from the above, that during the course of assessment ... total income of the assessee and brought to tax. Additions 4: Rs.1,35,61,158 /- As the above addition partakes the character of under-reporting of income, penalty is initiated u/s 270A of the I.T.Act,1961. 15.1 We have also gone through para no.4 of the order

Gujarat Energy Development Agency, Gandhinagar vs. The Dy.CIT, Circle-1, Exemp, Ahmedabad

In the result, the appeal of the assessee in ITA No

ITA 1180/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad16 Oct 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

Section 11Section 12ASection 143(3)Section 263Section 270A

Shah, Ld. AR of the assessee submitted that the Assessing Officer had initiated penalty proceeding under Section 270A of the Act for under-reporting of income. However, the penalty under Section 270A of the Act was imposed for misreporting of income, which was not correct. He submitted that there ... consequence of misreporting of income”. In the penalty order under Section 270A of the Act also, the Assessing Officer had levied penalty for “under-reporting of income which is in consequence of misreporting thereof”. As per the provisions of Section 270A(7) of the Act, penalty is required and levied

Gujarat Energy Development Agency, Gandhinagar vs. The Dy.CIT, Circle-1, Exemp, Ahmedabad

In the result, the appeal of the assessee in ITA No

ITA 1179/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad16 Oct 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

Section 11Section 12ASection 143(3)Section 263Section 270A

Shah, Ld. AR of the assessee submitted that the Assessing Officer had initiated penalty proceeding under Section 270A of the Act for under-reporting of income. However, the penalty under Section 270A of the Act was imposed for misreporting of income, which was not correct. He submitted that there ... consequence of misreporting of income”. In the penalty order under Section 270A of the Act also, the Assessing Officer had levied penalty for “under-reporting of income which is in consequence of misreporting thereof”. As per the provisions of Section 270A(7) of the Act, penalty is required and levied

Raghavan, Kanchipuram vs. ITO, Ncc-22(1), Tambaram

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

ITA 1776/CHNY/2025[2018-19]Status: DisposedITAT Chennai13 Oct 2025AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.1776/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 Raghavan, Vs. The Income Tax Officer, 3503, Bay View House, Hiraranan, Non Corporate Circle 22(1). 5/63, Omr, Egattur, Thazambur, Tambaram, Chennai. Kanchipuram District, Tamil Nadu. 600 130 [Pan:Ajjpv9178L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Y.Sridhar, F.C.A. ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 11.09.2025 घोषणा की तारीख /Date Of Pronouncement : 13.10.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 05.06.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2018-19. 2. The Assessee Raised 12 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is 2

For Appellant: Shri Y.Sridhar, F.C.AFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 139Section 139(1)Section 147Section 148Section 148ASection 270ASection 270A(1)Section 270A(2)(b)Section 274

section 148 of the Act, but, however, the Assessing Officer levied penalty under section 270A of the Act @ 200% of tax for alleged under-reporting of income, which is in consequence of misreporting of income for the AY 2018-19. We find that the ld. CIT(A) partly allowed

Sincere Architects Engineers Pvt. Ltd., Jaipur vs. ACIT, Cirlce-7, Jaipur

In the result the appeal no

ITA 974/JPR/2024[2017-18]Status: DisposedITAT Jaipur10 Oct 2025AY 2017-18
For Appellant: Shri Ashish Sharma, AdvFor Respondent: Shri Gaurav Awasthi, JCIT
Section 139Section 142(1)Section 147Section 148Section 154Section 194A

even within the extended time period allowed u/s.139(4) of the Act in spite of having taxable income. The appellant has under-reported its income as per the provisions of sub-clause (b) of clause (2) of Sec. 270A of the Income Tax Act, 1961. Hence the penalty order levied ... assessee of pre-paid taxes being more than the computed taxes holds no ground. Therefore, the A.O. imposed penalty u/s 270A for under-reporting of income. 7. The CIT(A) vide order dated 21.05.2024 confirmed the order on the ground that the return filed on 14.12.2021 was only after

Sincere Architects Engineers Pvt. Ltd., Jaipur vs. ACIT, Circle-7, Jaipur

In the result the appeal no

ITA 973/JPR/2024[2017-18]Status: DisposedITAT Jaipur10 Oct 2025AY 2017-18
For Appellant: Shri Ashish Sharma, AdvFor Respondent: Shri Gaurav Awasthi, JCIT
Section 139Section 142(1)Section 147Section 148Section 154Section 194A

even within the extended time period allowed u/s.139(4) of the Act in spite of having taxable income. The appellant has under-reported its income as per the provisions of sub-clause (b) of clause (2) of Sec. 270A of the Income Tax Act, 1961. Hence the penalty order levied ... assessee of pre-paid taxes being more than the computed taxes holds no ground. Therefore, the A.O. imposed penalty u/s 270A for under-reporting of income. 7. The CIT(A) vide order dated 21.05.2024 confirmed the order on the ground that the return filed on 14.12.2021 was only after

Hi-Tech Engineers, Mumbai vs. Central Circle 5(1), Bandra Mumbai

ITA 3166/MUM/2025[2019-20]Status: DisposedITAT Mumbai10 Oct 2025AY 2019-20

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Shri Bhavik ChhedaFor Respondent: Shri Ritesh Misra
Section 153ASection 270ASection 270A(2)Section 270A(2)(a)Section 270A(9)(a)Section 270A(9)(f)Section 69C

further submitted that in the penalty notices dated 30/09/2021 and 23/11/2023, the Assessing Officer had specified whether penalty was leviable for under-reporting of income in terms of Section 270A(2)(a) to 270A(2)(g) of the Act or for misreporting of income in terms of Section 270A ... joint reading of various provisions contained in Section 270A of the Act it becomes clear that on occurrence of the instance of under-reporting of income specified in Section 270A(2)(a) to 270A(2)(g) of the Act. In case the Assessing Officer arrives at a conclusion that

Hi-Tech Engineers, Mumbai vs. Central Circle 5(1), Bandra East, Mumbai

ITA 3165/MUM/2025[2018-19]Status: DisposedITAT Mumbai10 Oct 2025AY 2018-19

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Shri Bhavik ChhedaFor Respondent: Shri Ritesh Misra
Section 153ASection 270ASection 270A(2)Section 270A(2)(a)Section 270A(9)(a)Section 270A(9)(f)Section 69C

further submitted that in the penalty notices dated 30/09/2021 and 23/11/2023, the Assessing Officer had specified whether penalty was leviable for under-reporting of income in terms of Section 270A(2)(a) to 270A(2)(g) of the Act or for misreporting of income in terms of Section 270A ... joint reading of various provisions contained in Section 270A of the Act it becomes clear that on occurrence of the instance of under-reporting of income specified in Section 270A(2)(a) to 270A(2)(g) of the Act. In case the Assessing Officer arrives at a conclusion that