https://www.taxtmi.com/caselaws?id=784535 Penalty under s. 270A(1) r/w s. 270A(9)(c) was imposed on the footing that the assessee had made a false claim of expenses, leading to under-reported income, though the quantum addition sustained by CIT(A)/NFAC was only an ad hoc disallowance at 20% on an estimated basis. The Tribunal held that additions determined purely on estimate/ad hoc basis do not satisfy the statutory parameters for "under-reported income" attracting s. 270A, and further found absence of any recorded satisfaction by the AO establishing the requisite conditions for levy. Consequently, the penalty was held arbitrary and void ab initio and was quashed; the assessee's appeal was allowed. en-us Fri, 14 Nov 2025 00:00:00 +0530 Wed, 07 Jan 2026 08:03:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784535 Penalty under s. 270A(1) r/w s. 270A(9)(c) was imposed on the footing that the assessee had made a false claim of expenses, leading to under-reported income, though the quantum addition sustained by CIT(A)/NFAC was only an ad hoc disallowance at 20% on an estimated basis. The Tribunal held that additions determined purely on estimate/ad hoc basis do not satisfy the statutory parameters for "under-reported income" attracting s. 270A, and further found absence of any recorded satisfaction by the AO establishing the requisite conditions for levy. Consequently, the penalty was held arbitrary and void ab initio and was quashed; the assessee's appeal was allowed. Case-Laws Income Tax Fri, 14 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784535