https://www.taxtmi.com/caselaws?id=793803 Penalty under section 270A of the Income-tax Act was unsustainable where the assessee had fully disclosed the receipts and only the legal characterisation and taxability of those receipts in India were disputed. The tribunal noted that the assessee had stated the receipts were not taxable as royalty or fees for technical services under the Act and the India-Hong Kong DTAA, and the quantum addition arose only from a different view on that claim. In the absence of suppression of facts, under-reporting, misreporting, or any other ingredient of section 270A(9), penalty could not be sustained merely because the Revenue rejected the legal position. The deletion of penalty was upheld. en-us Fri, 19 Jun 2026 00:00:00 +0530 Wed, 24 Jun 2026 07:08:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793803 Penalty under section 270A of the Income-tax Act was unsustainable where the assessee had fully disclosed the receipts and only the legal characterisation and taxability of those receipts in India were disputed. The tribunal noted that the assessee had stated the receipts were not taxable as royalty or fees for technical services under the Act and the India-Hong Kong DTAA, and the quantum addition arose only from a different view on that claim. In the absence of suppression of facts, under-reporting, misreporting, or any other ingredient of section 270A(9), penalty could not be sustained merely because the Revenue rejected the legal position. The deletion of penalty was upheld. Case-Laws Income Tax Fri, 19 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793803