https://www.taxtmi.com/highlights?id=103006 Penalty for under-reporting under section 270A was inapplicable where lease-rental disallowance for non-deduction of tax at source arose from a bona fide, debatable interpretation of GNOIDA's status as a Government body. The taxpayer had disclosed the material facts, and neither the Assessing Officer nor the Commissioner (Appeals) found the explanation to lack bona fides. Confirmation of the underlying disallowance alone did not establish under-reporting for penalty purposes. The penalty was therefore deleted, applying the principle that an unsuccessful claim does not by itself justify penalty where the explanation is bona fide and fully disclosed. en-us Mon, 24 Aug 2026 08:33:56 +0530 Mon, 24 Aug 2026 08:33:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=103006 Penalty for under-reporting under section 270A was inapplicable where lease-rental disallowance for non-deduction of tax at source arose from a bona fide, debatable interpretation of GNOIDA's status as a Government body. The taxpayer had disclosed the material facts, and neither the Assessing Officer nor the Commissioner (Appeals) found the explanation to lack bona fides. Confirmation of the underlying disallowance alone did not establish under-reporting for penalty purposes. The penalty was therefore deleted, applying the principle that an unsuccessful claim does not by itself justify penalty where the explanation is bona fide and fully disclosed. Highlights Income Tax Mon, 24 Aug 2026 08:33:56 +0530 https://www.taxtmi.com/highlights?id=103006