https://www.taxtmi.com/caselaws?id=784321 Penalty under s. 270A for "under-reporting of income" was challenged where income was increased by (i) estimated disallowance of expenses and (ii) disallowance of interest u/s 40(a)(ia) for non-deduction of TDS. The ITAT held that estimated additions are excluded from s. 270A penalty only where the AO is satisfied that accounts are correct and complete but income cannot be properly deduced from the method employed; here, the AO had recorded that accounts were not correct/complete due to discrepancies and unsupported vouchers, and this was not rebutted, hence the case fell within s. 270A(2) and not s. 270A(6), so penalty was sustained. No arguments were made against penalty on the s. 40(a)(ia) disallowance, so it was also sustained, and the appeal was dismissed. en-us Wed, 31 Dec 2025 00:00:00 +0530 Fri, 02 Jan 2026 07:51:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784321 Penalty under s. 270A for "under-reporting of income" was challenged where income was increased by (i) estimated disallowance of expenses and (ii) disallowance of interest u/s 40(a)(ia) for non-deduction of TDS. The ITAT held that estimated additions are excluded from s. 270A penalty only where the AO is satisfied that accounts are correct and complete but income cannot be properly deduced from the method employed; here, the AO had recorded that accounts were not correct/complete due to discrepancies and unsupported vouchers, and this was not rebutted, hence the case fell within s. 270A(2) and not s. 270A(6), so penalty was sustained. No arguments were made against penalty on the s. 40(a)(ia) disallowance, so it was also sustained, and the appeal was dismissed. Case-Laws Income Tax Wed, 31 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784321