ITAT · Nagpur Bench2024(2024) 161 taxmann.com 712§270A

Ravindra Madhukar Kharche · ITAT Nagpur on §270A: 26AS-based variance from delayed bank reporting is not under-reporting

Does an interest-income variance caused by the bank's late reporting attract §270A?

No. Declaring interest per Form 26AS at filing, with variance arising from the bank's delayed reporting, is not under-reporting; §270A does not apply.

Reviewed by Adidam Sridhar, Deputy Commissioner of Income Tax (Retd.) · Published 2026-07-07

Facts in brief

  • The assessee declared interest income based on Form 26AS as it stood at filing.
  • A variance arose from the paying bank's delayed reporting after the ITR was filed.

Issue before the bench

Whether a post-filing 26AS variance constitutes under-reporting under §270A.

Held

No penalty under §270A applies where the variance traces to delayed third-party reporting rather than the assessee's suppression.

Practitioner takeaway

Archive the 26AS as on filing date with every return; it is the complete defence when reconciliations later shift.

Practice note · Adidam Sridhar, Deputy Commissioner of Income Tax (Retd.)

More on this topic: Penalties: §270A, §271D and the preconditions the Department skips · Need this drafted? Appeals Drafting for CA Firms: CIT(A) and ITAT

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