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Clause 440 of the Income Tax Bill, 2025, replaces Section 270AA of the Income-tax Act, 1961, providing a statutory framework for granting immunity from penalty and prosecution to taxpayers who pay due tax and interest within the prescribed time and do not file an appeal against the assessment order. The provision requires application within one month of receiving the assessment, mandates the assessing officer to decide within three months, and ensures natural justice by requiring an opportunity to be heard before rejecting immunity. Immunity is denied in cases involving serious defaults such as misreporting. Clause 440 largely mirrors Section 270AA but updates cross-references to new penalty and prosecution provisions and modifies references to assessment and appeal sections. The mechanism aims to encourage voluntary compliance, reduce litigation, and expedite revenue realization, while preserving deterrence against aggravated tax defaults. Procedural rules are to be prescribed, and the finality of immunity orders limits further appeals or revisions.
Clause 440 of the Income Tax Bill, 2025, replaces Section 270AA of the Income-tax Act, 1961, providing a statutory framework for granting immunity from penalty and prosecution to taxpayers who pay due tax and interest within the prescribed time and do not file an appeal against the assessment order. The provision requires application within one month of receiving the assessment, mandates the assessing officer to decide within three months, and ensures natural justice by requiring an opportunity to be heard before rejecting immunity. Immunity is denied in cases involving serious defaults such as misreporting. Clause 440 largely mirrors Section 270AA but updates cross-references to new penalty and prosecution provisions and modifies references to assessment and appeal sections. The mechanism aims to encourage voluntary compliance, reduce litigation, and expedite revenue realization, while preserving deterrence against aggravated tax defaults. Procedural rules are to be prescribed, and the finality of immunity orders limits further appeals or revisions.
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