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Penalty for misreporting under section 270A(9) requires a notice identifying the precise statutory instance alleged, because each form of misreporting calls for a distinct explanation. An assessment for the year preceding a search must follow the prescribed reassessment procedure, and an invalid assessment may be challenged in penalty proceedings where it forms the penalty's foundation. Voluntary disclosure of additional professional income, even if accepted in assessment, does not by itself establish misreporting. Section 271AAD addresses false entries or omissions linked to fraudulent input tax credit arrangements and does not extend merely to unrecorded professional receipts represented by cash found in search.
Penalty for misreporting under section 270A(9) requires a notice identifying the precise statutory instance alleged, because each form of misreporting calls for a distinct explanation. An assessment for the year preceding a search must follow the prescribed reassessment procedure, and an invalid assessment may be challenged in penalty proceedings where it forms the penalty's foundation. Voluntary disclosure of additional professional income, even if accepted in assessment, does not by itself establish misreporting. Section 271AAD addresses false entries or omissions linked to fraudulent input tax credit arrangements and does not extend merely to unrecorded professional receipts represented by cash found in search.
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