Penalty proceedings for alleged under-reporting or misreporting of income failed where the exact statutory limb was not specified. The ITAT treated the sweeping invocation of both limbs as non-application of mind and held the penalty unsustainable under the relevant provision. On identical facts, penalties for AY 2020-21 and AY 2019-20 were deleted, and deletion for AY 2018-19 was affirmed.
Penalty proceedings for alleged under-reporting or misreporting of income failed where the exact statutory limb was not specified. The ITAT treated the sweeping invocation of both limbs as non-application of mind and held the penalty unsustainable under the relevant provision. On identical facts, penalties for AY 2020-21 and AY 2019-20 were deleted, and deletion for AY 2018-19 was affirmed.
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