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Penalty and Compliance FAQs for Professionals

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Default Penalty / Consequence Section
Under-reporting of income 50% of tax on under-reported income 270A
Misreporting of income 200% of tax on under-reported income 270A(9)
Cash loan above ₹20,000 received 100% of amount received 271D
Cash loan above ₹20,000 repaid 100% of amount repaid 271E
Cash receipt above ₹2 lakh 100% of amount received 271DA
Wilful tax evasion Imprisonment 6 months to 7 years + fine 276C(1)
Non-filing of return Imprisonment 3 months to 2 years 276CC
Late TDS return ₹200 per day (capped at TDS amount) 234E
Immunity from 270A penalty File Form 68 within 1 month 270AA
All offences compoundable No time limit CBDT Oct 2024

Q1. The AO levied penalty under Section 270A for misreporting but did not specify which of the 8 limbs of Section 270A(9) applies. Is the penalty sustainable?

No — courts have consistently held this penalty unsustainable. The AO must specify the exact limb of Section 270A(9) being invoked. A general assertion of “misreporting” without identifying which specific category — misrepresentation of facts, false entry, suppression of receipts, etc. — is procedurally defective.

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