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    <title>2026 (5) TMI 1257 - ITAT DELHI</title>
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    <description>Section 270A penalty for under-reporting is discussed in the context of a taxpayer who had not filed a return under section 139(1), later filed a return in response to notice under section 148, and faced no variation in assessed income. The analysis notes that under-reporting may arise where no return is furnished or the first return is filed under section 148, but sub-section (6) excludes cases where the explanation is bona fide and all material facts are disclosed. Because the income was reflected in Form 26AS, the return was accepted as filed, and no addition was made, the explanation for non-filing was treated as bona fide and the penalty was deleted.</description>
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    <pubDate>Wed, 13 May 2026 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=792055</link>
      <description>Section 270A penalty for under-reporting is discussed in the context of a taxpayer who had not filed a return under section 139(1), later filed a return in response to notice under section 148, and faced no variation in assessed income. The analysis notes that under-reporting may arise where no return is furnished or the first return is filed under section 148, but sub-section (6) excludes cases where the explanation is bona fide and all material facts are disclosed. Because the income was reflected in Form 26AS, the return was accepted as filed, and no addition was made, the explanation for non-filing was treated as bona fide and the penalty was deleted.</description>
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