https://www.taxtmi.com/caselaws?id=793900 Penalty under Section 270A of the Income-tax Act could not be sustained where rectification orders recorded nil assessed income after adjustment of current year and brought forward losses, because the statutory precondition of under-reporting was absent. The Court treated the absence of under-reported income as the threshold defect and held that the penalty order failed on that basis. The later liquidation order and the Insolvency and Bankruptcy Code argument were noticed, but no final finding was recorded on them because they were not necessary once the penalty was unsustainable for want of under-reporting. The penalty was set aside in favour of the assessee. en-us Tue, 16 Jun 2026 00:00:00 +0530 Thu, 25 Jun 2026 08:27:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793900 Penalty under Section 270A of the Income-tax Act could not be sustained where rectification orders recorded nil assessed income after adjustment of current year and brought forward losses, because the statutory precondition of under-reporting was absent. The Court treated the absence of under-reported income as the threshold defect and held that the penalty order failed on that basis. The later liquidation order and the Insolvency and Bankruptcy Code argument were noticed, but no final finding was recorded on them because they were not necessary once the penalty was unsustainable for want of under-reporting. The penalty was set aside in favour of the assessee. Case-Laws Income Tax Tue, 16 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793900