https://www.taxtmi.com/caselaws?id=464148 ITAT CHENNAI - AT quashed penalty under s.270A(9), holding penalty is not mandatory and cannot be imposed without a discernible, specific satisfaction in the s.274 r.w.s.270A notice and a reasonable opportunity to be heard. The show-cause notice was vague as it did not specify whether proceedings were for "under-reporting" or "misreporting," rendering the penalty proceedings invalid. The Tribunal also found the AO's estimated disallowance of marketing expenses to be ad hoc and unsupported, and clauses invoked under s.270A(9) (d)/(e) inapplicable; appeal allowed and penalty set aside. en-us Wed, 06 Mar 2024 00:00:00 +0530 Tue, 07 Oct 2025 10:57:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464148 ITAT CHENNAI - AT quashed penalty under s.270A(9), holding penalty is not mandatory and cannot be imposed without a discernible, specific satisfaction in the s.274 r.w.s.270A notice and a reasonable opportunity to be heard. The show-cause notice was vague as it did not specify whether proceedings were for "under-reporting" or "misreporting," rendering the penalty proceedings invalid. The Tribunal also found the AO's estimated disallowance of marketing expenses to be ad hoc and unsupported, and clauses invoked under s.270A(9) (d)/(e) inapplicable; appeal allowed and penalty set aside. Case-Laws Income Tax Wed, 06 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464148