https://www.taxtmi.com/caselaws?id=768233 ITAT Mumbai ruled in favor of the assessee regarding penalties under sections 271(1)(c) and 270A. The assessee received payments from CSOD India for software distribution but claimed exemption under India-UK DTAA. Revenue treated CSOD India as assessee's DAPE and attributed income (reduced from 80% to 30% by DRP). ITAT held that merely making unsustainable claims cannot attract penalty for inaccurate particulars. The assessee cooperated fully during assessment and disclosed all material facts. Both penalties were deleted as the assessee's explanation was bonafide and exception under section 270A(6)(a) applied. en-us Fri, 28 Mar 2025 00:00:00 +0530 Thu, 03 Apr 2025 07:50:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768233 ITAT Mumbai ruled in favor of the assessee regarding penalties under sections 271(1)(c) and 270A. The assessee received payments from CSOD India for software distribution but claimed exemption under India-UK DTAA. Revenue treated CSOD India as assessee's DAPE and attributed income (reduced from 80% to 30% by DRP). ITAT held that merely making unsustainable claims cannot attract penalty for inaccurate particulars. The assessee cooperated fully during assessment and disclosed all material facts. Both penalties were deleted as the assessee's explanation was bonafide and exception under section 270A(6)(a) applied. Case-Laws Income Tax Fri, 28 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768233