Penalty u/s 270A - “underreporting” of income - right to be gra...

Penalty u/s 270A - “underreporting” of income - right to be granted immunity under Section 270AA - In the present case, the petitioner has satisfied the aforesaid conditions, inasmuch as, (i) the tax has been paid on the additions; (ii) appeal has undisputedly not been filed; and (iii) penalty (as would be evident from the penalty notice) has been initiated on account of “underreporting” of income. - the impugned order under Section 270A of the Act is set aside and the respondents are directed to grant immunity under Section 270AA - HC