https://www.taxtmi.com/caselaws?id=779625 ITAT CHENNAI - AT held that penalty under section 270A(2) could not be imposed as a matter of course where assessment additions arose from attribution of profits to a PE; penalty proceedings are distinct and discretionary, and imposition requires a fair opportunity to be heard. Applying the principle that penalty is not mandatory and considering the facts, the Tribunal found the case squarely within the exception in section 270A(6)(a) and directed the AO to cancel the penalty(s) levied under section 270A. en-us Fri, 26 Sep 2025 00:00:00 +0530 Thu, 09 Oct 2025 08:54:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779625 ITAT CHENNAI - AT held that penalty under section 270A(2) could not be imposed as a matter of course where assessment additions arose from attribution of profits to a PE; penalty proceedings are distinct and discretionary, and imposition requires a fair opportunity to be heard. Applying the principle that penalty is not mandatory and considering the facts, the Tribunal found the case squarely within the exception in section 270A(6)(a) and directed the AO to cancel the penalty(s) levied under section 270A. Case-Laws Income Tax Fri, 26 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779625