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The ITAT upheld the appellate authority's rectification of the penalty invocation under section 270A(9) from clause (e) to clause (a), sustaining penalty liability for misreporting/under-reporting undisclosed foreign-exchange gains not declared in the return filed under section 139(1). The Tribunal held that voluntary acceptance of quantum additions and lack of a separate quantum appeal do not extinguish penalty exposure where the income was previously undisclosed. The CIT(A)'s exercise of plenary, co-terminus powers with the Assessing Officer to correct the wrongly invoked clause was affirmed, and the order sustaining penalty under section 270A(9)(a) was decided against the assessee.
The ITAT upheld the appellate authority's rectification of the penalty invocation under section 270A(9) from clause (e) to clause (a), sustaining penalty liability for misreporting/under-reporting undisclosed foreign-exchange gains not declared in the return filed under section 139(1). The Tribunal held that voluntary acceptance of quantum additions and lack of a separate quantum appeal do not extinguish penalty exposure where the income was previously undisclosed. The CIT(A)'s exercise of plenary, co-terminus powers with the Assessing Officer to correct the wrongly invoked clause was affirmed, and the order sustaining penalty under section 270A(9)(a) was decided against the assessee.
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