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of <h1>Clarification on Section 273A(1): Penalty Waivers Must Be Separate for Different Assessment Years, Not Combined in One Order.</h1> The circular addresses the applicability of section 273A(1) of the Income Tax Act concerning the waiver of penalties. It clarifies that benefits under this section cannot be granted for disclosures made for different assessment years on different dates through a single order. The Ministry of Law advises that such disclosures must be treated separately to uphold the section's intent, which allows benefits only once in an assessee's lifetime. The circular emphasizes that disclosures should be voluntary and in good faith, and multiple defaults cannot be combined for a single waiver decision. This information should be communicated to relevant officers.
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