https://www.taxtmi.com/caselaws?id=800660 Section 270A(6)(a) excludes disclosed expenditure from under-reported income where the taxpayer gives a bona fide explanation and fully discloses material facts. Software-development expenditure, including impairment of an internally developed software asset and capital work-in-progress, was disclosed in audited financial statements. The dispute concerned whether that expenditure was revenue or capital in nature, not fictitious claims, inflated expenditure, false statements, or suppressed facts. Rejection of an arguable legal claim in quantum proceedings did not negate the bona fide explanation. The amount was therefore excluded from under-reported income and the penalty was deleted. en-us Wed, 30 Sep 2026 00:00:00 +0530 Fri, 09 Oct 2026 08:30:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800660 Section 270A(6)(a) excludes disclosed expenditure from under-reported income where the taxpayer gives a bona fide explanation and fully discloses material facts. Software-development expenditure, including impairment of an internally developed software asset and capital work-in-progress, was disclosed in audited financial statements. The dispute concerned whether that expenditure was revenue or capital in nature, not fictitious claims, inflated expenditure, false statements, or suppressed facts. Rejection of an arguable legal claim in quantum proceedings did not negate the bona fide explanation. The amount was therefore excluded from under-reported income and the penalty was deleted. Case-Laws Income Tax Wed, 30 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800660