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HC held that under Direct Tax Dispute Resolution Scheme, Section 204(3) renders orders conclusive and prohibits reopening matters. Once immunity is granted against penalty proceedings, the specific statutory provision (Section 271AAB or 271AB) becomes immaterial. The revision proceedings initiated based on audit objections to impose penalty under alternative statutory provision were unsustainable. The revenue's appeal was consequently dismissed, affirming the Tribunal's quashing of the revisional order and upholding the scheme's immunity provisions.
HC held that under Direct Tax Dispute Resolution Scheme, Section 204(3) renders orders conclusive and prohibits reopening matters. Once immunity is granted against penalty proceedings, the specific statutory provision (Section 271AAB or 271AB) becomes immaterial. The revision proceedings initiated based on audit objections to impose penalty under alternative statutory provision were unsustainable. The revenue's appeal was consequently dismissed, affirming the Tribunal's quashing of the revisional order and upholding the scheme's immunity provisions.
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