https://www.taxtmi.com/caselaws?id=470059 Penalty under Section 271A of the Income-tax Act, 1961 is presented as contingent on established under-reporting of income or misreporting resulting from such under-reporting. The material discussed indicates that, without a finding or evidentiary basis establishing either foundational condition, the provision cannot properly support a penalty. Accordingly, the penalty is described as legally unsustainable and liable to be deleted, with the issue treated as favouring the assessee. The notes focus on the requirement that the statutory preconditions for penalty must be demonstrated before the levy can be sustained. en-us Thu, 13 Mar 2025 00:00:00 +0530 Tue, 14 Jul 2026 19:02:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470059 Penalty under Section 271A of the Income-tax Act, 1961 is presented as contingent on established under-reporting of income or misreporting resulting from such under-reporting. The material discussed indicates that, without a finding or evidentiary basis establishing either foundational condition, the provision cannot properly support a penalty. Accordingly, the penalty is described as legally unsustainable and liable to be deleted, with the issue treated as favouring the assessee. The notes focus on the requirement that the statutory preconditions for penalty must be demonstrated before the levy can be sustained. Case-Laws Income Tax Thu, 13 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470059