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“penalty u/s 270A”

PenaltySection 270ASection 270A583 judgments

The decision most relied on for penalty u/s 270A is HCIL Arsspl Triveni (JV) v. ACIT ( (274 ITR 603), cited in 21 judgments on BharatTax.

Leading authorities on penalty u/s 270A

HCIL Arsspl Triveni (JV) v. ACIT (
274 ITR 603 · 2005 · High Court
21
citing judgments

An inaccurate claim made by the assessee cannot be treated as a case of giving inaccurate particulars of income for the purpose of imposing penalty.

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.

Judgments citing penalty u/s 270A

Shri Popat Karbhari Bhalerao, Nashik vs. Income Tax Officer, Ward.2(1), Pune

In the result, appeal of the assessee is allowed

ITA 1323/PUN/2023[2017-18]Status: DisposedITAT Pune26 Mar 2024AY 2017-18

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.1323 & 1324/Pun/2023 िनधा"रण वष" / Assessment Year : 2017-18 & 2018-19 Shri Popat Karbhari Bhalerao, The Income Tax Officer, Yeshdei Niwas, Maratha V Ward-2(1), Nashik. Nagar, Near Rajrajeshwari S Mangal Karyalay, Jailroad, Nashik Road, Nashik-422101. Pan: Aaqpb3523N Appellant / Assessee Respondent / Revenue Assessee By Shri Sanket Joshi – Ar Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 19/03/2024 Date Of Pronouncement 26/03/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Cit(A)[Nfac] For A.Y.2017-18 Dated 02.09.2022 Under Section 250 Of The Income Tax Act, 1961, Emanating From Penalty Order Under Section 270A Of The Act, Dated 30.12.2021. The Assessee Raised The Following Grounds Of Appeal :

Section 147Section 24Section 250Section 270ASection 270A(9)Section 270A(9)(e)Section 274Section 9

raised the following grounds of appeal : ITA Nos.1323 & 1324/PUN/2023 Shri Popat Karbhari Bhalarao [A] “1. The learned CIT-(A) erred in confirming the penalty u/s 270A of Rs.2,60,874 levied by the A.O without appreciating that the said levy of penalty was not justified on facts ... assessee submits that in the reassessment order, the A.O has initiated penalty u/s 270A on a vague charge of ‘furnishing inaccurate particulars of income’ also in the notice u/s 274 r.w.s 270A, the exact limb of section 270A(9) which has been allegedly violated by the assessee has not been

Income Tax Officer, Ward-1, Jalna, Aayakr Bhawan, Siraswadi Road, Nr Tv. Centre vs. Mahesh Nagari Sahakari Pathsanstha Limited, Sarojinidevi Road, Jalna

In the result, appeal of the Revenue is dismissed

ITA 1228/PUN/2023[2018]Status: DisposedITAT Pune26 Mar 2024

Bench: Shri Partha Sarathi Chaudhuryand Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1228/Pun/2023 िनधा"रण वष" / Assessment Year :2018-19 The Income Tax Officer, Mahesh Nagari Ward-1, Jalna. V Sahakaripathastha Limited, S 14, Swami Complex, First Floor, Sarojinidevi Road, Jalna – 431203. Pan: Aaaam5643C Appellant / Revenue Respondent /Assessee Assessee By None. Revenue By Shri R.Y.Balawade – Addl.Cit Date Of Hearing 11/03/2024 Date Of Pronouncement 26/03/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Revenue Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 Dated 26.09.2023 For A.Y.2018-19 Emanating From Penalty Order Under Section 270A Of The Act Dated 01.10.2021. The Grounds Of Appeal Raised By The Revenue Are As Under : “I) On The Fact & In The Circumstances Of The Case, The Ld. Cit(A) Has Erred In Deletion Of Penalty U/S 270A Of The Act As Levied By The Ao. Mahesh Nagari Sahakari Pathsanstha [R]

Section 250Section 270ASection 80P(2)(a)

under : “i) On the fact and in the circumstances of the case, the Ld. CIT(A) has erred in deletion of penalty u/s 270A of the Act as levied by the AO. Mahesh Nagari Sahakari Pathsanstha [R] ii) On the fact and in the circumstances of the case ... erred in deleting the penalty u/s 270A by allowing deduction u/s 80P(2)(a)(i) of the Act without appreciating the fact that the assessee has earned interest on investment which is not allowable for such deduction. iii) Any other ground of appeal that may be urged at the time

Sachanand Relumal Jagwani, Pune vs. ITO Ward 7(3), Pune

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

ITA 1044/PUN/2023[2018-19]Status: DisposedITAT Pune26 Mar 2024AY 2018-19

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.1044/Pun/2023 िनधा"रण वष" / Assessment Year : 2018-19 Sachanand Relumal Jagwani, The Income Tax Officer, Bunglow No.1/20, Marrygold V Ward-7(3), Pune. Co-Op Housing Society, Behind S Gold Adlab Theatre, Kalyani Nagar, Pune – 411014. Pan: Aaxpj1950B Appellant / Assessee Respondent / Revenue Assessee By Shri Hari Krishan – Ar Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 19/03/2024 Date Of Pronouncement 26/03/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals) Passed Under Section 250 Of The Income Tax Act, 1961 Dated 03.08.2023 Confirming The Penalty Under Section 270A Of The Act. Grounds Of Appeal Raised By The Assessee Are As Under : “1. The Ld. Commissioner Of Income Tax (Appeals) Has Erred In Not Deciding On Merits The Followings Grounds Taken In The Grounds Of Appeal. (A) The Assessing Officer Has Eared In Levying Penalty Of Sachanand Relumal Jagwani [A]

Section 250Section 270ASection 275

impugned appellate order, only to the violation of procedural aspect of the provisions of section 275 of the Income Tax Act. 3. Penalty u/s 270A of the Income Tax Act is not attracted in this case as the additions/disallowances made in the assessment order are not sustainable on the facts

Jaina Marketing & Associates, Delhi vs. DCIT, Central Circle-18, Delhi

Accordingly, Appeals filed by the assessee are allowed

ITA 226/DEL/2023[2019-20]Status: DisposedITAT Delhi20 Mar 2024AY 2019-20

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

Section 132Section 153ASection 270ASection 270A(9)Section 270A(9)(a)Section 271(1)(c)Section 271ASection 274

misreporting its income, to the tune of Rs.3,94,996/-. Therefore, I am satisfied that it is a fit case for levy of penalty u/s 270A of the Income Tax Act, 1961. The amount of penalty that is to be levied for the fault of under reporting income in consequence ... been confirmed by the Ld. CIT(A) on the same reasoning. The question is whether the AO's action to levy penalty u/s 270A(9) of the Act is sustainable in the given facts of the case. In order to examine that let us have a look at relevant provisions

Jaina Marketing & Associates, Delhi vs. DCIT, Central Circle-18, Delhi

Accordingly, Appeals filed by the assessee are allowed

ITA 225/DEL/2023[2018-19]Status: DisposedITAT Delhi20 Mar 2024AY 2018-19

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

Section 132Section 153ASection 270ASection 270A(9)Section 270A(9)(a)Section 271(1)(c)Section 271ASection 274

misreporting its income, to the tune of Rs.3,94,996/-. Therefore, I am satisfied that it is a fit case for levy of penalty u/s 270A of the Income Tax Act, 1961. The amount of penalty that is to be levied for the fault of under reporting income in consequence ... been confirmed by the Ld. CIT(A) on the same reasoning. The question is whether the AO's action to levy penalty u/s 270A(9) of the Act is sustainable in the given facts of the case. In order to examine that let us have a look at relevant provisions

Jaina Marketing & Associates, Delhi vs. DCIT, Central Circle-18, Delhi

Accordingly, Appeals filed by the assessee are allowed

ITA 224/DEL/2023[2017-18]Status: DisposedITAT Delhi20 Mar 2024AY 2017-18

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

Section 132Section 153ASection 270ASection 270A(9)Section 270A(9)(a)Section 271(1)(c)Section 271ASection 274

misreporting its income, to the tune of Rs.3,94,996/-. Therefore, I am satisfied that it is a fit case for levy of penalty u/s 270A of the Income Tax Act, 1961. The amount of penalty that is to be levied for the fault of under reporting income in consequence ... been confirmed by the Ld. CIT(A) on the same reasoning. The question is whether the AO's action to levy penalty u/s 270A(9) of the Act is sustainable in the given facts of the case. In order to examine that let us have a look at relevant provisions

Shri Adinath Vasantrao Wandhekar, Ahmednagar vs. Income Tax Office, Ward-4, Panvel, Mumbai

The appeal of the assessee stands ALLOWED

ITA 1388/PUN/2023[2018-19]Status: DisposedITAT Pune08 Mar 2024AY 2018-19

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 1388/Pun/2023 निर्धारण वषा / Assessment Year : 2018-19 Adinath Vasantrao Wandhekar, At Post-Shevgaon, Davakinadan Khandoba Ngr., Ahmednagar-414502 Pan: Aaepw7481P . . . . . . . अपीलार्थी / Appellant

For Appellant: Mr Prasad Bhandari [‘Ld. AR’]For Respondent: Mr Ramnath Murkunde [Ld. DR’]
Section 10Section 10(10)Section 10(10)(i)Section 143(3)Section 250Section 270ASection 270A(8)

determined taxes. In view of the acceptance of addition made on account of disallowance of full claim of exemption, the tax authorities levied penalty u/s 270A @ the accelerated rate of 200% of tax sought to be evaded by mis-reporting the nature of employment held vis-à-vis excess claims

Satyam Print House, Mumbai vs. Additional /Joint/ Deputy/Assistant Commissioner of Income Tax, Income Tax Officer, NFAC, Delhi

ITA 2898/MUM/2023[ 2018-19]Status: DisposedITAT Mumbai08 Mar 2024

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Pritesh MehtaFor Respondent: Shri Prashant Mahajan
Section 270ASection 50CSection 56(2)(x)

eyes of law. 2. The CIT(A) has erred in law and on facts in upholding the levy of penalty u/s 270A in respect of addition made under section 50C. 3. The CIT(A) has erred in law and on facts in upholding the levy of penalty u/s 270A ... fact the transaction of sale has taken place at prevailing market price. 4 The CIT(A) has erred in upholding the levy of penalty u/s 270A rejecting the contention of the assessee that the sale price is the actual price of property and no penalty u/s 270A can be levied

Suresh Productions, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

In the result, appeal of assessee is allowed

ITA 642/HYD/2023[2017-18]Status: DisposedITAT Hyderabad29 Feb 2024AY 2017-18

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri A. Srinivas, ARFor Respondent: Shri Waseem UR Rehman, DR
Section 270Section 270ASection 270A(9)Section 9

this case reads that,- “8. By considering facts of the case, I am satisfied that this is a fit case for levy of penalty u/s 270A for under reporting of income in consequence of misreporting as the assessee has under reported the income in the return of income ... equal to two hundred per cent of the amount of tax payable on under-reported income. 10. The amount considered for levy of penalty u/s 270A(9) is Rs. Rs.30,000/- and tax payable on the same works out to be Rs.10,382/-. Hence, Penalty leviable u/s 270A

First Abu Dhabi Bank Pjsc, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-Circle 2(3)(1), Mumbai

In the result, the appeal of the assessee is partly allowed

ITA 3279/MUM/2023[2020-21]Status: DisposedITAT Mumbai27 Feb 2024AY 2020-21

Bench: Shri Amit Shukla & Shri Amarjit Singhfirst Abu Dhabi Bank Vs. Deputy Commissioner Of Pjsc, Unit No.1101 & Income-Tax (It), Circle 1201 Platina Building, C- 2(3)(1), Room No. 1614, 59, G Block, Bandra Kurla 16Th Floor, Air India Complex, Bandra East, Building, Nariman Point, Mumbai – 400051 Mumbai – 400021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaecn2845F Appellant .. Respondent Appellant By : Madhur Agarwal Respondent By : Anil Sant Date Of Hearing 07.02.2024 Date Of Pronouncement 27.02.2024 आदेश / O R D E R Per Amarjit Singh (Am): This Appeal Filed By The Assessee Is Directed Against The Order Passed By The Deputy Commissioner Of Income Tax, International Taxation, Circle 2(3)(1), Mumbai-2, Dated 20.07.2023 For A.Y. 2020-21. The Assessee Has Raised The Following Grounds Before Us: 1. Ground No. 1: The Learned Ao Has, On The Facts & Circumstances Of The Case & In Law, Erred In Initiating & Completing Assessment Proceedings Under Section 143(3) Of The Act Without Issuing A Valid Notice Under Section 143(2) Of The Act Ie, The Notice Under Section 143(2) Of The Act Dated 29 June 2021 For Initiating Assessment Was Issued By National Faceless Assessment Centre (Nafac) Instead Of Being Issued By The Learned Ao (I.E Jurisdictional Assessing Officer) 2. Ground No. 2:

For Appellant: Madhur AgarwalFor Respondent: Anil Sant
Section 143(2)Section 143(3)Section 153Section 155(18)Section 270ASection 80G

First Abu Dhabi Bank Vs. DCIT(IT) Circle 2(3)(1) 17. This ground of appeal is related to initiation of penalty u/s 270A of the Act for misreporting of income in relation to deduction of health and education cess. The assessee submitted that it has filed form

R.Muralidhara, Chennai vs. ITO, Chew-110-1, Chennai

The appeal stand allowed for statistical purposes

ITA 450/CHNY/2023[2018-19]Status: DisposedITAT Chennai26 Feb 2024AY 2018-19

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Shri Manomohan Das, Hon’Ble Jm

For Appellant: ShriM. Karunakaran (Advocate) – Ld. ARFor Respondent: ShriR. Clement Ramesh Kumar (CIT) –Ld. DR
Section 133(6)Section 143(3)Section 270ASection 40

grounds as well as the appeal stand allowed for statistical purposes. 7. In ITA No.450/Chny/2023, the assessee is aggrieved by levy of consequential penalty u/s 270A. The penalty order would show that the assessee has remained non-compliant during penalty proceedings. The Ld. CIT(A) has confirmed the penalty against

R.Muralidhara, Chennai vs. ITO, Che-W-(110)(1), Chennai

The appeal stand allowed for statistical purposes

ITA 449/CHNY/2023[2018-19]Status: DisposedITAT Chennai26 Feb 2024AY 2018-19

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Shri Manomohan Das, Hon’Ble Jm

For Appellant: ShriM. Karunakaran (Advocate) – Ld. ARFor Respondent: ShriR. Clement Ramesh Kumar (CIT) –Ld. DR
Section 133(6)Section 143(3)Section 270ASection 40

grounds as well as the appeal stand allowed for statistical purposes. 7. In ITA No.450/Chny/2023, the assessee is aggrieved by levy of consequential penalty u/s 270A. The penalty order would show that the assessee has remained non-compliant during penalty proceedings. The Ld. CIT(A) has confirmed the penalty against

Bharat Agro Industries, Bhiwani vs. DCIT Circle, Bhiwani

In the result, the appeal of the assessee is allowed

ITA 3934/DEL/2023[2017-18]Status: HeardITAT Delhi23 Feb 2024AY 2017-18

Bench: Shri Kul Bharat[Assessment Year : 2017-18] Bharat Agro Industries, Vs Dcit, Devsar Mod, Opp. Delhi Police Circle Bhiwani. School, Loharu Road, Bhiwani, Haryana-127021. Pan-Aamfb0628H Appellant Respondent Appellant By Shri Gautam Jain, Adv., Shri Lalit Mohan, Adv. & Shri Parth Singhal, Adv. Respondent By Shri Om Parkash, Sr.Dr Date Of Hearing 21.02.2024 Date Of Pronouncement 23.02.2024

Section 115BSection 143(2)Section 143(3)Section 68

made by the AO of Rs.39,27,414/- is sustained. Ground no.1 & 3 are dismissed. 8. Ground No.2 is relating to initiation of penalty u/s 270A of the Act. As the penalty is merely initiated and not levied, this ground is pre- mature. Hence, ground No.2 is dismissed.” 9. From

Shri Premprakashishprakash Sharma, Nashik vs. Income Tax Officer, Ward-2(1), Nashik

ITA 19/PUN/2024[2018-19]Status: HeardITAT Pune20 Feb 2024AY 2018-19

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

For Appellant: Shri Sanket JoshiFor Respondent: Shri Sourabh Nayak, Addl.CIT
Section 147Section 249(2)Section 270ASection 270A(9)Section 274

Coca Cola India (P) Ltd. [368 ITR 487]. 5. Without prejudice to the above grounds, the assessee submits that the levy of penalty u/s 270A is also not justified on merits and hence, the same may please be deleted. 6. The appellant craves leave to add/alter/amend any of the grounds

Shri Premprakashishprakash Sharma, Nashik vs. Income Tax Officer, Wrd-2(1), Pune

ITA 18/PUN/2024[2017-18]Status: HeardITAT Pune20 Feb 2024AY 2017-18

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

For Appellant: Shri Sanket JoshiFor Respondent: Shri Sourabh Nayak, Addl.CIT
Section 147Section 249(2)Section 270ASection 270A(9)Section 274

Coca Cola India (P) Ltd. [368 ITR 487]. 5. Without prejudice to the above grounds, the assessee submits that the levy of penalty u/s 270A is also not justified on merits and hence, the same may please be deleted. 6. The appellant craves leave to add/alter/amend any of the grounds

Prem Prakash Agarwal, Naya Bazar Ajmer vs. DCIT Central Circle Ajmer, Jaipur Road Ajmer

In the result, the appeal of the assessee is allowed

ITA 757/JPR/2023[2017-18]Status: DisposedITAT Jaipur09 Feb 2024AY 2017-18

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. C. M. Agarwal (CA)For Respondent: Sh. Ajay Malik (CIT)
Section 153ASection 270ASection 270A(1)Section 274

facts and in the circumstances of the case and in law the order passed by Ld. CIT (A) for confirming penalty u/s 270A of Income Tax Act, 1961 is wrong, bad in law, invalid and void-ab-initio as the ld. AO initiated the penalty u/s 270A of Income ... facts and in the circumstances of the case and in law the order passed by Ld. CIT(A) for confirming penalty u/s 270A of Income Tax Act, 1961 is wrong, bad in law, invalid and void-ab-initio as the the ld. AO issued notice under section 274 r.w.s 270A

Mgg Infra Projects Private Limited, Ajmer vs. Income Tax Officer, Delhi

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

ITA 728/JPR/2023[2017-18]Status: DisposedITAT Jaipur08 Feb 2024AY 2017-18

Bench: Sh. Sandep Gosain & Dr. M. L. Meena

For Appellant: NoneFor Respondent: Sh. Monisha Chaudhary, Addl. CIT
Section 244ASection 250Section 270A

NFAC, Delhi dated 03/03/2023 in respect of the Assessment Year: 2017-18 challenging therein confirmation of levy of penalty u/s 270A of the Act amounting to ₹1,96,362/-. 2 MGG Infra Projects Pvt. Ltd. v. ITO 2. None appeared on behalf of the assessee nor any adjournment application

New Skies Satellites B.V., Gurgaon vs. DCIT, Circle-2(2)(2), International Taxation, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 2944/DEL/2022[2020-21]Status: DisposedITAT Delhi06 Feb 2024AY 2020-21

Bench: Shri G.S.Pannu & Shri Kul Bharat[Assessment Year : 2020-21] New Skies Satellites B.V., Vs Dcit, C/O-Ernst & Young Llp, Golf Cirlce-2(2)(2), View Corporate Tower, Tower-B, International Taxation, Sector-42, Gurgaon, New Delhi. Haryana-122002. Pan-Aaccn1866C Appellant Respondent Appellant By Ms. Ananya Bajpayee, Adv. Respondent By Shri Bhuvnesh Kulshrestha, Cit Dr & Shri Om Prakash, Sr.Dr Date Of Hearing 12.01.2024 Date Of Pronouncement 06.02.2024

Section 139(1)Section 143(1)Section 2Section 234ASection 270ASection 9(1)(vi)

This ground being consequential in nature, we hold accordingly. 12. Ground No.6 raised by the assessee is against the initiating of penalty u/s 270A of the Act. This ground is pre-mature hence, dismissed. 13. In the result, appeal of the assessee is partly allowed. Order pronounced in the open

Prathamesh Vivek Khot, Mumbai vs. Income Tax Officer Circle 41 2 1, Mumbai

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

ITA 2602/MUM/2023[2017-18]Status: DisposedITAT Mumbai31 Jan 2024AY 2017-18

Bench: Shri Vikas Awasthy, Jm & Shri Prashant Maharishi, Am Income Tax Officer, Prathamesh Vivek Khot 1502-1503 Dreams 1-A Wing, National E-Assessment Lbs Marg Bhandup (W), Centre, Delhi Vs. Mumbai-400 078 Maharashtra-400 078 (Appellant) (Respondent) Pan No. Bsbpk6695K Assessee By : Shri Mandar Vaidya, Ar Revenue By : Shri H.M. Bhatt, Dr Date Of Hearing: 18.12.2023 Date Of Pronouncement : 31.01.2024

For Appellant: Shri Mandar Vaidya, ARFor Respondent: Shri H.M. Bhatt, DR
Section 142Section 270ASection 270A(9)Section 54FSection 9

learned CIT (A) failed to note that the appellant had a meritorious case in quantum proceedings and hence the question of levy of penalty u/s 270A did not arise. 2. The learned CIT (A) fell in error of law in not appreciating that, the Appellant was holding one residential house

Give Foundation, Bangalore vs. The Dy.CIT, Circle-1(Exemption), Ahmedabad

In the result, the primary matter involved in all the Assessment

ITA 795/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad29 Jan 2024AY 2017-18

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Ms. Urvashi Sodhan, A.RFor Respondent: Shri Ramesh Kumar, Sr. D.R
Section 11Section 12ASection 2(15)Section 234BSection 25Section 251(2)Section 270ASection 8

enhancement of income without issuing show cause notice u/s 251(2) of the Act. Tax Effect: NIL, being technical ground. 9. Initiation of penalty u/s 270A is not justified, 10. Charging of Interest u/s 234B, 234C, 234D are” 3. Before us, the counsel for the assessee submitted that the issue