https://www.taxtmi.com/caselaws?id=469516 Penalty under section 270A requires statutory under-reporting of income and a real tax impact. A disallowance of depreciation under section 11(6) on assets treated earlier as application of income does not, by itself, establish under-reporting when the assessee's returned income and assessed income are both nil. Where the income remains exempt under section 11 and the disallowance creates no taxable income, tax payable, loss reduction, or conversion of loss into income, the conditions in section 270A(2) are not met. The penalty provision is strictly construed and cannot be invoked merely because a claim is disallowed. en-us Tue, 09 Dec 2025 00:00:00 +0530 Fri, 19 Jun 2026 19:55:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469516 Penalty under section 270A requires statutory under-reporting of income and a real tax impact. A disallowance of depreciation under section 11(6) on assets treated earlier as application of income does not, by itself, establish under-reporting when the assessee's returned income and assessed income are both nil. Where the income remains exempt under section 11 and the disallowance creates no taxable income, tax payable, loss reduction, or conversion of loss into income, the conditions in section 270A(2) are not met. The penalty provision is strictly construed and cannot be invoked merely because a claim is disallowed. Case-Laws Income Tax Tue, 09 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469516