https://www.taxtmi.com/caselaws?id=799999 Penalty under section 271AAC(1) could not be sustained where the assessment order repeatedly recorded satisfaction for misreporting of income and initiated penalty proceedings under section 270A. The two penalty regimes are not interchangeable because section 271AAC(2) excludes section 270A penalty for income covered by section 271AAC(1). A subsequent notice under section 274 cannot retrospectively replace the statutory basis or satisfaction recorded in the assessment order. Failure to provide a meaningful hearing, where electronic registration and postal service were unsuccessful, also breached section 274. The penalty was therefore invalid and liable to deletion. en-us Fri, 18 Sep 2026 00:00:00 +0530 Wed, 30 Sep 2026 08:41:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799999 Penalty under section 271AAC(1) could not be sustained where the assessment order repeatedly recorded satisfaction for misreporting of income and initiated penalty proceedings under section 270A. The two penalty regimes are not interchangeable because section 271AAC(2) excludes section 270A penalty for income covered by section 271AAC(1). A subsequent notice under section 274 cannot retrospectively replace the statutory basis or satisfaction recorded in the assessment order. Failure to provide a meaningful hearing, where electronic registration and postal service were unsuccessful, also breached section 274. The penalty was therefore invalid and liable to deletion. Case-Laws Income Tax Fri, 18 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799999