https://www.taxtmi.com/caselaws?id=797541 Penalty for under-reporting cannot rest solely on confirmation of a disallowance where lease-rental payments were made without tax deduction under a bona fide, disclosed and debatable interpretation that GNOIDA was a Government body exempt from the deduction requirement. The applicability of tax deduction at source depended on GNOIDA's status and raised an interpretational issue. Statutory protection remains available unless the explanation lacks bona fides or relevant material facts were not disclosed. Accordingly, the lease-rental disallowance did not constitute under-reporting of income, and penalty under Section 270A was unsustainable. en-us Mon, 03 Aug 2026 00:00:00 +0530 Mon, 24 Aug 2026 08:33:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797541 Penalty for under-reporting cannot rest solely on confirmation of a disallowance where lease-rental payments were made without tax deduction under a bona fide, disclosed and debatable interpretation that GNOIDA was a Government body exempt from the deduction requirement. The applicability of tax deduction at source depended on GNOIDA's status and raised an interpretational issue. Statutory protection remains available unless the explanation lacks bona fides or relevant material facts were not disclosed. Accordingly, the lease-rental disallowance did not constitute under-reporting of income, and penalty under Section 270A was unsustainable. Case-Laws Income Tax Mon, 03 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797541