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Misreporting penalty under section 270A needs a specific statutory limb and clear linkage to the additions before it can survive.

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Full Text of the Document

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....Penalty for misreporting under section 270A requires the assessing authority to identify the precise limb in section 270A(9) and explain how the additions satisfy that clause. A mere ad hoc disallowance of labour or loading and unloading charges, or a disallowance based on alleged non-deduction of tax at source, does not by itself establish misreporting of income. The text also notes that email-only appellate notices, when the assessee had opted for another mode, do not justify an adverse inference from non-appearance. On that reasoning, the penalty was deleted.....