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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 Bilal Ahmad Sathoo, Anantnag vs. Income Tax Officer Ward, Udhampur

The appeals stand allowed for statistical purposes

ITA 421/ASR/2024[2017-18]Status: DisposedITAT Amritsar27 Oct 2025AY 2017-18

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Udayan Das Gupta, Jm 1. आयकर अपील सं. / Ita No. 420/Asr/2024 (िनधा"रण वष" / Assessment Year: 2017-18) & 2. आयकर अपील सं. / Ita No. 421/Asr/2024 (िनधा"रण वष" / Assessment Year: 2017-18) Shri Bilal Ahmad Sathoo Ito M/S Fair Deal Agencies बनाम/ Ward Udhampur Salfia Market, Anantnag (J&K) Vs. H.O. 192101 (J&K) "ायी लेखा सं./Pan. Bkrps-0522-B (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant By : Shri. Mohad Iqbal Untoo (Ca) - Ld. Ar ""थ"कीओरसे/Respondent By : Shri Charan Dass (Addl. Cit)- Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 15-10-2025 घोषणाकीतारीख /Date Of Pronouncement : 27/10/2025 आदेश / O R D E R Manoj Kumar Aggarwal () In Aforesaid Twin Appeals For Assessment Year (Ay) 2017-18, 1. The Assessee Is Aggrieved By Confirmation Of Quantum Addition For Rs.112.44 Lacs & Confirmation Of Consequential Penalty U/S 270A For Rs.19.38 Lacs. The Registry Has Noted Delay Of 150 Days In Quantum Appeal Ita No.420/Asr/2024, The Condonation Of Which Has Been Sought By Ld. Ar On The Strength Of Condonation Petition

For Appellant: Shri. Mohad Iqbal Untoo (CA) - Ld. ARFor Respondent: Shri Charan Dass (Addl. CIT)- Ld. Sr. DR
Section 270A

Assessment Year (AY) 2017-18, 1. the assessee is aggrieved by confirmation of quantum addition for Rs.112.44 Lacs and confirmation of consequential penalty u/s 270A for Rs.19.38 Lacs. The registry has noted delay of 150 days in quantum appeal ITA No.420/Asr/2024, the condonation of which has been sought

Shri Bilal Ahmad Sathoo, Anantnag vs. Income Tax Officer -Ward, Udhampur

The appeals stand allowed for statistical purposes

ITA 420/ASR/2024[2017-18]Status: DisposedITAT Amritsar27 Oct 2025AY 2017-18

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Udayan Das Gupta, Jm 1. आयकर अपील सं. / Ita No. 420/Asr/2024 (िनधा"रण वष" / Assessment Year: 2017-18) & 2. आयकर अपील सं. / Ita No. 421/Asr/2024 (िनधा"रण वष" / Assessment Year: 2017-18) Shri Bilal Ahmad Sathoo Ito M/S Fair Deal Agencies बनाम/ Ward Udhampur Salfia Market, Anantnag (J&K) Vs. H.O. 192101 (J&K) "ायी लेखा सं./Pan. Bkrps-0522-B (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant By : Shri. Mohad Iqbal Untoo (Ca) - Ld. Ar ""थ"कीओरसे/Respondent By : Shri Charan Dass (Addl. Cit)- Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 15-10-2025 घोषणाकीतारीख /Date Of Pronouncement : 27/10/2025 आदेश / O R D E R Manoj Kumar Aggarwal () In Aforesaid Twin Appeals For Assessment Year (Ay) 2017-18, 1. The Assessee Is Aggrieved By Confirmation Of Quantum Addition For Rs.112.44 Lacs & Confirmation Of Consequential Penalty U/S 270A For Rs.19.38 Lacs. The Registry Has Noted Delay Of 150 Days In Quantum Appeal Ita No.420/Asr/2024, The Condonation Of Which Has Been Sought By Ld. Ar On The Strength Of Condonation Petition

For Appellant: Shri. Mohad Iqbal Untoo (CA) - Ld. ARFor Respondent: Shri Charan Dass (Addl. CIT)- Ld. Sr. DR
Section 270A

Assessment Year (AY) 2017-18, 1. the assessee is aggrieved by confirmation of quantum addition for Rs.112.44 Lacs and confirmation of consequential penalty u/s 270A for Rs.19.38 Lacs. The registry has noted delay of 150 days in quantum appeal ITA No.420/Asr/2024, the condonation of which has been sought

Mahesh Tukaram Matkar, Nashik vs. Income Tax Officer, Nashik

In the result, both the appeals filed by the assessee are dismissed

ITA 2350/PUN/2024[2018-19]Status: DisposedITAT Pune27 Oct 2025AY 2018-19

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: NoneFor Respondent: Shri Deepak Kumar Kedia
Section 139(1)Section 142(1)Section 147Section 148Section 270ASection 270A(1)Section 274

upheld the order of the Ld. CIT(A) / NFAC. Following similar reasonings, the order of the Ld. CIT(A) / NFAC upholding the penalty u/s 270A of the Act is upheld and the grounds raised by the assessee are dismissed. 10. In the result, both the appeals filed by the assessee

Mahesh Tukaram Matkar, Nashik vs. Income Tax Officer, Nashik

In the result, both the appeals filed by the assessee are dismissed

ITA 2342/PUN/2024[2017-18]Status: DisposedITAT Pune27 Oct 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: NoneFor Respondent: Shri Deepak Kumar Kedia
Section 139(1)Section 142(1)Section 147Section 148Section 270ASection 270A(1)Section 274

upheld the order of the Ld. CIT(A) / NFAC. Following similar reasonings, the order of the Ld. CIT(A) / NFAC upholding the penalty u/s 270A of the Act is upheld and the grounds raised by the assessee are dismissed. 10. In the result, both the appeals filed by the assessee

Rakesh Kumar Gupta, Delhi vs. Ld. ITO, Ward 35(1), Delhi

In the result, the appeal of the assessee is allowed

ITA 3447/DEL/2025[2021-22]Status: DisposedITAT Delhi27 Oct 2025AY 2021-22

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2021-22] Rakesh Kumar Gupta, Income Tax Officer, Ward-35(1), B-2/38, Ground Floor, E-2, Civic Centre, Delhi-110002 Ashok Vihar, Phase-Ii, Vs Delhi-110052 Pan-Aafhr8657H Appellant Respondent

Section 115JSection 143Section 143(3)Section 148Section 250Section 270A

National Faceless Assessment Centre, Delhi, pertaining to Assessment Year 2021-22. 2. Contesting the order of ld. CIT(A) dated 31.03.2025 confirming penalty u/s 270A imposed by the ld. AO amounting to Rs.19,40,453/-, the assessee has raised following grounds of appeal:- 1. Ld. CIT(A) has erred both

N. Vijay Kumar, ACIT, Chennai vs. Rajah Muthiah Chettiar Charitable and Educational Trust, Chennai

In the result, appeals filed by the Revenue & CO of assessee are

ITA 2097/CHNY/2025[2019-20]Status: DisposedITAT Chennai24 Oct 2025AY 2019-20

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr. Arjunraj, AdvocateFor Respondent: Mr. Saujanya Ranjan, IRS
Section 270ASection 270A(9)Section 9

issued by the AO u/s.274 r.w.s.270A of the Act. In absence of any particular charge for which, the assessee is directed to pay penalty u/s 270A of the Act, entire penalty proceedings becomes invalid and liable to be quashed. 19. In this view of the matter and by following

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)

that when a notice u/s 270A of the Act is issued, the following step ladder should be followed by the AO while levying penalty u/s 270A of the Act. 1. Underreporting — First the onus is on the AO to establish whether any of the contingency spoken of in clauses ... cause which of the specific action of the assessee company from clause (a) to (f) of Section 270A(9) was determinant before imposing penalty u/s 270A of the Act has rendered the proceedings invalid and thus untenable in the eyes of law.” 6.5.10 In the present case, on examination

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)

that when a notice u/s 270A of the Act is issued, the following step ladder should be followed by the AO while levying penalty u/s 270A of the Act. 1. Underreporting — First the onus is on the AO to establish whether any of the contingency spoken of in clauses ... cause which of the specific action of the assessee company from clause (a) to (f) of Section 270A(9) was determinant before imposing penalty u/s 270A of the Act has rendered the proceedings invalid and thus untenable in the eyes of law.” 6.5.10 In the present case, on examination

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)

that when a notice u/s 270A of the Act is issued, the following step ladder should be followed by the AO while levying penalty u/s 270A of the Act. 1. Underreporting — First the onus is on the AO to establish whether any of the contingency spoken of in clauses ... cause which of the specific action of the assessee company from clause (a) to (f) of Section 270A(9) was determinant before imposing penalty u/s 270A of the Act has rendered the proceedings invalid and thus untenable in the eyes of law.” 6.5.10 In the present case, on examination

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)

that when a notice u/s 270A of the Act is issued, the following step ladder should be followed by the AO while levying penalty u/s 270A of the Act. 1. Underreporting — First the onus is on the AO to establish whether any of the contingency spoken of in clauses ... cause which of the specific action of the assessee company from clause (a) to (f) of Section 270A(9) was determinant before imposing penalty u/s 270A of the Act has rendered the proceedings invalid and thus untenable in the eyes of law.” 6.5.10 In the present case, on examination

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)

that when a notice u/s 270A of the Act is issued, the following step ladder should be followed by the AO while levying penalty u/s 270A of the Act. 1. Underreporting — First the onus is on the AO to establish whether any of the contingency spoken of in clauses ... cause which of the specific action of the assessee company from clause (a) to (f) of Section 270A(9) was determinant before imposing penalty u/s 270A of the Act has rendered the proceedings invalid and thus untenable in the eyes of law.” 6.5.10 In the present case, on examination

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)

that when a notice u/s 270A of the Act is issued, the following step ladder should be followed by the AO while levying penalty u/s 270A of the Act. 1. Underreporting — First the onus is on the AO to establish whether any of the contingency spoken of in clauses ... cause which of the specific action of the assessee company from clause (a) to (f) of Section 270A(9) was determinant before imposing penalty u/s 270A of the Act has rendered the proceedings invalid and thus untenable in the eyes of law.” 6.5.10 In the present case, on examination

Karyon Healthy Co Forever LLP, Pune vs. ITO, Ward 7(3), Pune

ITA 1563/PUN/2025[2020-21]Status: DisposedITAT Pune16 Oct 2025AY 2020-21

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri Abhilash HiranFor Respondent: Shri Deepak Kumar Kedia (Virtual)
Section 142(1)Section 143(1)Section 143(3)Section 270A

also allowed for statistical purposes. ITA No.1560/PUN/2025, A.Y. 2018-19: 13. The issue involves in this appeal is levy of penalty u/s 270A of the Act levied by the Assessing Officer and confirmed by Ld. CIT(A)/NFAC. Since we have set-aside the order passed ... with a direction to decide the appeal afresh on merits of the case after providing reasonable opportunity of hearing, therefore, the issue of penalty u/s 270A of the Act is also set-aside with a direction to decide the penalty appeal afresh upon disposal of quantum appeal. Accordingly, the appeal

Karyon Healthy Co Forever LLP, Pune vs. ITO, Ward 7(3), Pune

ITA 1562/PUN/2025[2020-21]Status: DisposedITAT Pune16 Oct 2025AY 2020-21

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri Abhilash HiranFor Respondent: Shri Deepak Kumar Kedia (Virtual)
Section 142(1)Section 143(1)Section 143(3)Section 270A

also allowed for statistical purposes. ITA No.1560/PUN/2025, A.Y. 2018-19: 13. The issue involves in this appeal is levy of penalty u/s 270A of the Act levied by the Assessing Officer and confirmed by Ld. CIT(A)/NFAC. Since we have set-aside the order passed ... with a direction to decide the appeal afresh on merits of the case after providing reasonable opportunity of hearing, therefore, the issue of penalty u/s 270A of the Act is also set-aside with a direction to decide the penalty appeal afresh upon disposal of quantum appeal. Accordingly, the appeal

Karyon Healthy Co Forever LLP, Pune vs. ITO, Ward 7(3), Pune

ITA 1561/PUN/2025[2018-19]Status: DisposedITAT Pune16 Oct 2025AY 2018-19

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri Abhilash HiranFor Respondent: Shri Deepak Kumar Kedia (Virtual)
Section 142(1)Section 143(1)Section 143(3)Section 270A

also allowed for statistical purposes. ITA No.1560/PUN/2025, A.Y. 2018-19: 13. The issue involves in this appeal is levy of penalty u/s 270A of the Act levied by the Assessing Officer and confirmed by Ld. CIT(A)/NFAC. Since we have set-aside the order passed ... with a direction to decide the appeal afresh on merits of the case after providing reasonable opportunity of hearing, therefore, the issue of penalty u/s 270A of the Act is also set-aside with a direction to decide the penalty appeal afresh upon disposal of quantum appeal. Accordingly, the appeal

Karyon Healthy Co Forever LLP, Pune vs. ITO, Ward 7(3), Pune

ITA 1560/PUN/2025[2018-19]Status: DisposedITAT Pune16 Oct 2025AY 2018-19

Bench: Shri R. K. Panda & Shri Vinay Bhamore

For Appellant: Shri Abhilash HiranFor Respondent: Shri Deepak Kumar Kedia (Virtual)
Section 142(1)Section 143(1)Section 143(3)Section 270A

also allowed for statistical purposes. ITA No.1560/PUN/2025, A.Y. 2018-19: 13. The issue involves in this appeal is levy of penalty u/s 270A of the Act levied by the Assessing Officer and confirmed by Ld. CIT(A)/NFAC. Since we have set-aside the order passed ... with a direction to decide the appeal afresh on merits of the case after providing reasonable opportunity of hearing, therefore, the issue of penalty u/s 270A of the Act is also set-aside with a direction to decide the penalty appeal afresh upon disposal of quantum appeal. Accordingly, the appeal

Hamid Ali, Rohtas vs. ITO, Ward- 3 (4), Sasaram

In the result, ITA No.356/Pat/2025 is partly allowed for statistical purposes and ITA No

ITA 357/PAT/2025[2018-19]Status: DisposedITAT Patna10 Oct 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Rakesh Mishraita Nos.356 & 357/Pat/2025 Assessment Years: 2018-19 Hamid Ali…..……………..……………………….……….……….……Appellant C/O Gulam Murtaza Zakki Shaheed, Sasaram, Rohtas, Bihar – 821115. [Pan: Atppa8563N] Vs. Ito, Ward-3(4), Sasaram.…………………………….....……...…..…..Respondent Appearances By: Shri A.K. Rastogi, Sr. Adv. & Shri Rakesh Kumar, Advocate, Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 06, 2025 Date Of Pronouncing The Order : October 10, 2025 Order Per Madhumita Roy: Both The Appeals Filed By The Assessee Are Directed Against The Separate Orders Both Dated 12.12.2024 Passed By Nfac, Delhi Arising Out Of The Orders Dated 23.02.2021 & 23.08.2021 Passed U/S 143(3) & U/S 270A Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”] Respectively For Assessment Year 2018-19. Ita No.356/Pat/2025 Relates To Quantum Order Whereas Ita No.357/Pat/2025 Relates To Penalty Order.

Section 143(3)Section 270ASection 50C(2)(a)Section 53C

instant appeal of the assessee is allowed for statistical purposes. 6. ITA No.357/Pat/2025 – As the issue in the instant appeal is relating to penalty u/s 270A which is consequential to the quantum order in ITA No.356/Pat/2025 which we have already discussed, therefore, the penalty has no legs to stand

Hamid Ali, Rohtas vs. ITO, Ward- 3 (4), Sasaram

In the result, ITA No.356/Pat/2025 is partly allowed for statistical purposes and ITA No

ITA 356/PAT/2025[2018-19]Status: DisposedITAT Patna10 Oct 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Rakesh Mishraita Nos.356 & 357/Pat/2025 Assessment Years: 2018-19 Hamid Ali…..……………..……………………….……….……….……Appellant C/O Gulam Murtaza Zakki Shaheed, Sasaram, Rohtas, Bihar – 821115. [Pan: Atppa8563N] Vs. Ito, Ward-3(4), Sasaram.…………………………….....……...…..…..Respondent Appearances By: Shri A.K. Rastogi, Sr. Adv. & Shri Rakesh Kumar, Advocate, Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 06, 2025 Date Of Pronouncing The Order : October 10, 2025 Order Per Madhumita Roy: Both The Appeals Filed By The Assessee Are Directed Against The Separate Orders Both Dated 12.12.2024 Passed By Nfac, Delhi Arising Out Of The Orders Dated 23.02.2021 & 23.08.2021 Passed U/S 143(3) & U/S 270A Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”] Respectively For Assessment Year 2018-19. Ita No.356/Pat/2025 Relates To Quantum Order Whereas Ita No.357/Pat/2025 Relates To Penalty Order.

Section 143(3)Section 270ASection 50C(2)(a)Section 53C

instant appeal of the assessee is allowed for statistical purposes. 6. ITA No.357/Pat/2025 – As the issue in the instant appeal is relating to penalty u/s 270A which is consequential to the quantum order in ITA No.356/Pat/2025 which we have already discussed, therefore, the penalty has no legs to stand

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

penalty for non-filing of return is provided u/s 271F of the Act 2. The CIT(A) has erred in confirming the penalty u/s 270A of Rs.17,60,910/- both in law and in facts, which makes his cryptic order unsustainable, and liable to be quashed ... filed within due date. Only because the appellant was subjected to TDS on its receipts does not make the appellant immune from penalty u/s 270A of the Act. The appellant was required to file Return of Income within the due date. The appellant failed to do so. Hence

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

penalty for non-filing of return is provided u/s 271F of the Act 2. The CIT(A) has erred in confirming the penalty u/s 270A of Rs.17,60,910/- both in law and in facts, which makes his cryptic order unsustainable, and liable to be quashed ... filed within due date. Only because the appellant was subjected to TDS on its receipts does not make the appellant immune from penalty u/s 270A of the Act. The appellant was required to file Return of Income within the due date. The appellant failed to do so. Hence