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    <title>2025 (12) TMI 1519 - ITAT DELHI</title>
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    <description>Penalty under s. 270A was levied on the premise that excess purchases, arising from improper accounting of purchase returns, constituted under-reporting in consequence of misreporting under s. 270A(9)(a). The Tribunal held that misreporting requires misrepresentation or suppression of facts, which was absent because the assessee furnished an explanation for the discrepancy and the addition resulted from the AO&#039;s non-acceptance of that explanation during assessment. The assessee&#039;s non-filing of further appeal and payment of tax to &quot;buy peace,&quot; coupled with seeking immunity under s. 270AA, did not establish misreporting. Penalty was deleted and the appeal was allowed.</description>
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    <pubDate>Tue, 23 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 1519 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=783979</link>
      <description>Penalty under s. 270A was levied on the premise that excess purchases, arising from improper accounting of purchase returns, constituted under-reporting in consequence of misreporting under s. 270A(9)(a). The Tribunal held that misreporting requires misrepresentation or suppression of facts, which was absent because the assessee furnished an explanation for the discrepancy and the addition resulted from the AO&#039;s non-acceptance of that explanation during assessment. The assessee&#039;s non-filing of further appeal and payment of tax to &quot;buy peace,&quot; coupled with seeking immunity under s. 270AA, did not establish misreporting. Penalty was deleted and the appeal was allowed.</description>
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      <pubDate>Tue, 23 Dec 2025 00:00:00 +0530</pubDate>
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