https://www.taxtmi.com/caselaws?id=772779 The ITAT Delhi held that penalty under section 270A for under-reporting of income cannot be imposed when the assessee disclosed all relevant facts in the ITR. The AO disallowed deduction claims under section 35(2AB) based on Form 3CL, but this disallowance alone does not constitute under-reporting since the assessee made genuine claims based on available information. The tribunal emphasized that penalty requires demonstration of concealment or furnishing inaccurate particulars, which was absent here. The assessee's claim was based on books of accounts with reasonable cause, particularly as Form 3CL was issued seven months after ITR filing. Penalty deleted in favor of assessee. en-us Fri, 23 May 2025 00:00:00 +0530 Fri, 17 Jul 2026 10:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772779 The ITAT Delhi held that penalty under section 270A for under-reporting of income cannot be imposed when the assessee disclosed all relevant facts in the ITR. The AO disallowed deduction claims under section 35(2AB) based on Form 3CL, but this disallowance alone does not constitute under-reporting since the assessee made genuine claims based on available information. The tribunal emphasized that penalty requires demonstration of concealment or furnishing inaccurate particulars, which was absent here. The assessee's claim was based on books of accounts with reasonable cause, particularly as Form 3CL was issued seven months after ITR filing. Penalty deleted in favor of assessee. Case-Laws Income Tax Fri, 23 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772779