https://www.taxtmi.com/caselaws?id=796795 Penalty for under-reporting under section 270A does not arise merely because disclosed income is reclassified from capital gains to dividend income. Where returned and assessed total income remain identical, the receipt was fully disclosed, and reclassification reduces tax liability, there is no suppression or under-reporting. A bona fide explanation supported by disclosure of all material facts falls within the protection under section 270A(6)(a). Penalty is discretionary rather than automatic upon a change in the head of income. On these facts, penalty was not leviable and was directed to be deleted. en-us Thu, 16 Jul 2026 00:00:00 +0530 Tue, 11 Aug 2026 08:47:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796795 Penalty for under-reporting under section 270A does not arise merely because disclosed income is reclassified from capital gains to dividend income. Where returned and assessed total income remain identical, the receipt was fully disclosed, and reclassification reduces tax liability, there is no suppression or under-reporting. A bona fide explanation supported by disclosure of all material facts falls within the protection under section 270A(6)(a). Penalty is discretionary rather than automatic upon a change in the head of income. On these facts, penalty was not leviable and was directed to be deleted. Case-Laws Income Tax Thu, 16 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796795