https://www.taxtmi.com/caselaws?id=799311 Penalty for under-reporting or misreporting is not attracted where a CSR-related deduction claim is supported by binding precedent and the underlying addition is deleted. An education cess deduction claimed under then-binding jurisdictional precedent, but relinquished after a retrospective amendment reversed that position, does not warrant penalty. Under the APA framework, timely filing of a modified return requires total income to conform to the agreement; a royalty adjustment thereby resolved, with complete disclosure, does not constitute under-reporting, misrepresentation or suppression. These principles exclude penalty where claims were legally supported when made and relevant transactions were fully disclosed. en-us Wed, 09 Sep 2026 00:00:00 +0530 Sat, 19 Sep 2026 08:20:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799311 Penalty for under-reporting or misreporting is not attracted where a CSR-related deduction claim is supported by binding precedent and the underlying addition is deleted. An education cess deduction claimed under then-binding jurisdictional precedent, but relinquished after a retrospective amendment reversed that position, does not warrant penalty. Under the APA framework, timely filing of a modified return requires total income to conform to the agreement; a royalty adjustment thereby resolved, with complete disclosure, does not constitute under-reporting, misrepresentation or suppression. These principles exclude penalty where claims were legally supported when made and relevant transactions were fully disclosed. Case-Laws Income Tax Wed, 09 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799311