https://www.taxtmi.com/caselaws?id=786731 A transfer pricing addition based on arm's length price estimation does not by itself establish misreporting for penalty under Section 270A. Misreporting requires statutory ingredients such as misrepresentation, suppression, false entries, or failure to report transactions; where the assessee maintained the prescribed records under Section 92D and disclosed the international transaction and material facts, the exclusion in Section 270A(6)(d) applied. On that basis, immunity under Section 270AA was available and the penalty could not be sustained. The High Court accordingly set aside the penalty and the rejection of immunity. en-us Fri, 06 Feb 2026 00:00:00 +0530 Wed, 18 Feb 2026 08:12:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786731 A transfer pricing addition based on arm's length price estimation does not by itself establish misreporting for penalty under Section 270A. Misreporting requires statutory ingredients such as misrepresentation, suppression, false entries, or failure to report transactions; where the assessee maintained the prescribed records under Section 92D and disclosed the international transaction and material facts, the exclusion in Section 270A(6)(d) applied. On that basis, immunity under Section 270AA was available and the penalty could not be sustained. The High Court accordingly set aside the penalty and the rejection of immunity. Case-Laws Income Tax Fri, 06 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786731