In the assessment of Ms. Nandini for tax year 2026-27, the Assessing Officer finds under-reported…

A "claim of expenditure not substantiated by any evidence" is one of the cases of misreporting listed in section 439(11), and section 439(10) fixes the penalty for under-reported income caused by misreporting at "200% of the tax payable on under-reported income". The 50% rate in section 439(9) is for plain under-reporting. The figure of 100% belongs to section 440, where additional income-tax paid in lieu of penalty can earn waiver and immunity.