https://www.taxtmi.com/caselaws?id=793695 Penalty under section 270A is not automatic on every disallowance. The note states that where a charitable trust's depreciation claim is disallowed under section 11(6) but, after giving effect to appellate relief, the assessed income remains nil and no tax is payable, the statutory element of under-reporting is not established in any legally relevant sense. In the absence of tax advantage, loss reduction with statutory consequence, or other tax effect, penalty under section 270A cannot be sustained and is deleted. en-us Tue, 19 May 2026 00:00:00 +0530 Mon, 22 Jun 2026 08:39:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793695 Penalty under section 270A is not automatic on every disallowance. The note states that where a charitable trust's depreciation claim is disallowed under section 11(6) but, after giving effect to appellate relief, the assessed income remains nil and no tax is payable, the statutory element of under-reporting is not established in any legally relevant sense. In the absence of tax advantage, loss reduction with statutory consequence, or other tax effect, penalty under section 270A cannot be sustained and is deleted. Case-Laws Income Tax Tue, 19 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793695