2026 (8) TMI 1258

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....ct, 1961 vide order dated 29.09.2025. 2. Brief Facts of the Case 2.1. The assessee is an individual who filed her Return of Income for A.Y. 2018-19 on 21.07.2018, declaring a total income of Rs. 8,75,330/-, which included agricultural income amounting to Rs. 6,45,930/-. 2.2. The case was selected for scrutiny, and an assessment under Section 143(3) of the Act was completed on 06.04.2021. In the assessment order, the Assessing Officer (AO) made an addition of Rs. 1,08,12,000/- on account of interest received on enhanced compensation on land. The total interest received was Rs. 2,16,24,000/-, and after granting a statutory deduction of 50% under Section 57(iv) of the Act (i.e., Rs. 1,08,12,000/-), the net amount of Rs. 1,08,12,000/- ....

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....s an exempt income and therefore, the same was duly been show as exempt income in the return of income. The said view was fortified by decisions of various Tribunals. The Ld. AR further stated that when different views are possible, penalty cannot be levied. 2.7 On the other hand, the learned Departmental Representative (Ld. DR) relied upon the orders of the lower authorities and argued that the addition was based on interest on enhanced compensation on land was not declared by the assessee in the return of income, justifying the levy of penalty under Section 270A. Findings & Decision 3. We have heard the rival contentions, perused the material available on record, and carefully considered the applicable statutory provisions alongs....