https://www.taxtmi.com/caselaws?id=470224 Deletion of the quantum additions removed the foundation and computational basis for penalty for under-reporting or misreporting of income. As no under-reported income or tax payable remained after the assessee was found eligible for exemption and the additions, including disallowance of guarantee-claim provisions, were deleted, the penalty could not survive. Pendency of a challenge to the quantum order did not justify retaining the penalty, and a later prospective amendment was irrelevant because liability had to be assessed under the law applicable on the alleged default date. The Section 270A penalty was therefore directed to be deleted. en-us Mon, 15 Sep 2025 00:00:00 +0530 Mon, 20 Jul 2026 20:32:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470224 Deletion of the quantum additions removed the foundation and computational basis for penalty for under-reporting or misreporting of income. As no under-reported income or tax payable remained after the assessee was found eligible for exemption and the additions, including disallowance of guarantee-claim provisions, were deleted, the penalty could not survive. Pendency of a challenge to the quantum order did not justify retaining the penalty, and a later prospective amendment was irrelevant because liability had to be assessed under the law applicable on the alleged default date. The Section 270A penalty was therefore directed to be deleted. Case-Laws Income Tax Mon, 15 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470224