Penalty under 270A of Income Tax - Income Tax

Dear Experts Our client s case was reopened u/s 147 of Income Tax Act 1961 . We have filed Return u/s 148 accordingly. Factual Position: Return of Income as per Original Return of Income was Rs. 10,05,000.00 The reason and issue while opening the case was that the interest income from bank was not shown. Return of Income as per 148 Return was Rs. 16,55,000.00 hence Income was increased by Rs, 6,50,000.00. The increased income is Interest income which was shown on accrual basis instead of receipt basis. Our Scrutiny was completed with Income assessed as 16,70,000.00. Income Added Rs, 15,000.00 Order u/s 147: AO has initiated Penalty proceeding u/s 270A(9) of Income Tax Act i.e. underreporting in the form of Misreporting on following additional Income i.e. Income Assessee Rs. 16,70,000.00 minus Income as per Original Return Rs. 10,05,000.00 i.e. Rs. 6,65,000.00 We are of opinion that Penalty should be levied on only on addition made during scrutiny i.e. Rs. 15,000.00. Please advised, We also request to provide any case law regarding same matter if available.