Ayush Saxena, a former Tata employee who moved to the United States in August 2018, faced an ₹8.29 lakh penalty after the Income Tax Department alleged he had under‑reported ₹26.06 lakh of salary income.
He voluntarily paid ₹1.62 lakh in self‑assessment tax on 23 August 2019, along with interest and a late fee, hoping the matter would close quietly. No reassessment had started when he made the payment, and he maintained that the omission was a compliance lapse amid relocation.
After the department reopened the case under Section 148, Saxena filed a return declaring ₹20.49 lakh of income. The assessing officer accepted the return but initiated penalty proceedings under Section 270A, labeling the disclosure as misreporting.
The ITAT Jaipur’s SMC bench—Accountant Member Annapurna Gupta and Judicial Member Kuldip Singh—heard the appeal. Chartered Accountant Suresh Surana explained that Section 270A(2)(b) allows for under‑reporting when a taxpayer first discloses income in a Section 148 response, but Section 270A(6)(a) excludes such income if the taxpayer offers a bona fide explanation and full disclosure. Surana cited Saxena’s history of timely filings, his immediate payment of tax and fees, and the fact that the reassessment was opened almost three years after his voluntary settlement as evidence that the omission was unintentional.
The tribunal ruled in Saxena’s favour on 17 August 2026, canceling the ₹8.29 lakh penalty and restoring his compliance record. He said the decision lifts a heavy burden, allowing him to resume future filings while working abroad without fear of further sanctions.