https://www.taxtmi.com/caselaws?id=781783 ITAT Mumbai-AT allowed the assessee's appeal and deleted the penalty levied u/s 270A. It held that the difference between returned and assessed income did not constitute "under reported income" in view of the exclusion in s. 270A(6)(a). The assessee's original return was based on Form 26AS then available; later-updated entries and a gross-up omission were voluntarily corrected before any statutory notice. All relevant Form 26AS reconciliations, computations, TDS certificates, and primary documents were fully disclosed, and all income had already suffered TDS, causing no revenue loss. In absence of contumacious conduct or concealment, penalty was held unsustainable. en-us Mon, 17 Nov 2025 00:00:00 +0530 Thu, 20 Nov 2025 08:42:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781783 ITAT Mumbai-AT allowed the assessee's appeal and deleted the penalty levied u/s 270A. It held that the difference between returned and assessed income did not constitute "under reported income" in view of the exclusion in s. 270A(6)(a). The assessee's original return was based on Form 26AS then available; later-updated entries and a gross-up omission were voluntarily corrected before any statutory notice. All relevant Form 26AS reconciliations, computations, TDS certificates, and primary documents were fully disclosed, and all income had already suffered TDS, causing no revenue loss. In absence of contumacious conduct or concealment, penalty was held unsustainable. Case-Laws Income Tax Mon, 17 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781783