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Income Tax - Highlights / Catch Notes

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ITAT held that penalty u/s 270A is unsustainable where deduction ...


Legal Win: Tax Deduction Claim Transparently Made Before Amendment Leads to Penalty Reversal Under Section 270A Decision

April 26, 2025

Case Laws     Income Tax     AT

ITAT held that penalty u/s 270A is unsustainable where deduction claim was made transparently based on existing legal interpretation prior to retrospective amendment. The assessee voluntarily surrendered the claim upon becoming aware of amendment and fully disclosed facts during assessment proceedings. No allegation of concealment or suppression existed. Relying on judicial precedent, the tribunal concluded that bona fide interpretation of law, even if subsequently found incorrect, does not attract penalty. The assessee's appeal was allowed, restricting penalty imposition.

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