Penalty u/s 270A - immunity u/s 270AA - misreporting of income -...

Penalty u/s 270A - immunity u/s 270AA - misreporting of income - there is not even a whisper as to which limb of Section 270A of the Act is attracted and how the ingredient of sub-section (9) of Section 270A is satisfied. In the absence of such particulars, the mere reference to the word "misreporting" by the Respondents in the penalty order to deny immunity from imposition of penalty and prosecution makes the impugned order manifestly arbitrary. - HC