Section 270A penalties cannot rest on disclosed APA adjustments, precedent-supported CSR claims, or later retrospective education-cess amendments.

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....Section 270A penalties for under-reporting or misreporting are inapplicable where an Advance Pricing Agreement governs a modified return, the royalty transaction is fully disclosed, and the revised arm's-length royalty rate is reflected in total income. A CSR expenditure deduction claim should not attract penalty where supported by binding Tribunal precedent, particularly if the underlying addition is deleted. Likewise, an education cess claim made under then-prevailing High Court precedent should not be penalised merely because a later retrospective amendment requires its withdrawal. These principles preserve the APA framework and protect bona fide, disclosed claims subsequently displaced by legal change.....