https://www.taxtmi.com/highlights?id=80078 Assessee failed to justify receipt discrepancy between ITR and Form 26AS, AO made addition considering it as fees for technical services and imposed penalty u/s 270A for under-reporting income. ITAT held penalty order silent on assessee's submissions, penalty notice lacked specific allegation of misrepresentation/suppression, and subsequent rectification of Form 26AS removed discrepancy. Relying on Supreme Court judgment, ITAT set aside penalty considering entirety of circumstances and allowed assessee's grounds. en-us Sat, 03 Aug 2024 08:09:28 +0530 Sat, 03 Aug 2024 08:09:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=80078 Assessee failed to justify receipt discrepancy between ITR and Form 26AS, AO made addition considering it as fees for technical services and imposed penalty u/s 270A for under-reporting income. ITAT held penalty order silent on assessee's submissions, penalty notice lacked specific allegation of misrepresentation/suppression, and subsequent rectification of Form 26AS removed discrepancy. Relying on Supreme Court judgment, ITAT set aside penalty considering entirety of circumstances and allowed assessee's grounds. Highlights Income Tax Sat, 03 Aug 2024 08:09:28 +0530 https://www.taxtmi.com/highlights?id=80078