Computational Errors in Tax Assessment Do Not Constitute Underreported Income, Tribunal Clarifies Section 270A Penalty Provisions

ITAT adjudicated a taxation dispute concerning penalty levy under section 270A. The tribunal examined whether disallowed expenses constituted underreported income. Key findings indicate that adjustments made under section 143(1)(a) involving apparent computational mistakes do not qualify as underreported income warranting penalty. The tribunal distinguished between inadvertent computational errors and deliberate income misreporting. Specifically, additions made during assessment that stem from apparent mistakes are exempt from penalty provisions. The tribunal interpreted section 270A(2)(a) narrowly, holding that only income determined through scrutiny assessment can be classified as underreported. Consequently, the tribunal ruled in favor o..... .....

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