https://www.taxtmi.com/caselaws?id=467706 Penalty under section 270A was unsustainable where the assessee claimed deduction of education cess as business expenditure on a bona fide, disclosed interpretation supported by earlier judicial views. The issue remained genuinely debatable until the retrospective clarification in the Finance Act, 2022, and the Revenue did not establish under-reporting, misreporting, mala fide concealment, or deliberate furnishing of inaccurate particulars. Shifting descriptions of the charge also weakened the penalty basis. On these facts, the claim could not be treated as actionable misreporting, and the penalty was directed to be deleted. en-us Tue, 18 Mar 2025 00:00:00 +0530 Mon, 30 Mar 2026 11:43:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467706 Penalty under section 270A was unsustainable where the assessee claimed deduction of education cess as business expenditure on a bona fide, disclosed interpretation supported by earlier judicial views. The issue remained genuinely debatable until the retrospective clarification in the Finance Act, 2022, and the Revenue did not establish under-reporting, misreporting, mala fide concealment, or deliberate furnishing of inaccurate particulars. Shifting descriptions of the charge also weakened the penalty basis. On these facts, the claim could not be treated as actionable misreporting, and the penalty was directed to be deleted. Case-Laws Income Tax Tue, 18 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467706