No Under reporting no Penalty

Does failing to file a return automatically mean you under-reported income? Delhi ITAT says no.

The taxpayer filed his return in response to Section 148, declared the entire income, and the Department accepted it without any variation. 

With the salary and TDS already reflected in Form 26AS, the Tribunal found his belief that tax had already been discharged to be bona fide. A filing default may be a compliance failure—but it is not automatically under-reporting for Section 270A