https://www.taxtmi.com/caselaws?id=784708 Penalty under s. 270A for "under-reporting" was held unsustainable where the assessee's claimed business loss was not disallowed but only recharacterised by the AO as speculative loss. Relying on HC precedent, the Tribunal held that mere change in the head/sub-head of loss, without any material showing concealment or furnishing of inaccurate particulars, does not establish under-reporting or a wilful default; accordingly, the penalty was deleted. The fact that the assessee did not further contest the quantum addition was held irrelevant because penalty proceedings are independent and require proof of culpable conduct; the appeal against penalty was allowed. en-us Fri, 02 Jan 2026 00:00:00 +0530 Sat, 10 Jan 2026 08:25:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784708 Penalty under s. 270A for "under-reporting" was held unsustainable where the assessee's claimed business loss was not disallowed but only recharacterised by the AO as speculative loss. Relying on HC precedent, the Tribunal held that mere change in the head/sub-head of loss, without any material showing concealment or furnishing of inaccurate particulars, does not establish under-reporting or a wilful default; accordingly, the penalty was deleted. The fact that the assessee did not further contest the quantum addition was held irrelevant because penalty proceedings are independent and require proof of culpable conduct; the appeal against penalty was allowed. Case-Laws Income Tax Fri, 02 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784708