https://www.taxtmi.com/caselaws?id=445900 The ITAT Amritsar ruled in favor of the assessee regarding penalty immunity under Section 271AAA. The AO imposed penalty claiming immunity was lost due to delayed tax payment per Settlement Commission order. The assessee paid only 30 lacs initially with balance outstanding. The tribunal held that while payment was delayed, the assessee ultimately complied with ITSC directions. Relying on SC precedent, the tribunal noted ITSC's power to extend payment periods. Since no undisclosed income was specified during search proceedings under Section 132(4), immunity under Section 271AAA(2)(i) applied. The penalty was deleted. en-us Mon, 21 Aug 2023 00:00:00 +0530 Wed, 22 Nov 2023 07:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445900 The ITAT Amritsar ruled in favor of the assessee regarding penalty immunity under Section 271AAA. The AO imposed penalty claiming immunity was lost due to delayed tax payment per Settlement Commission order. The assessee paid only 30 lacs initially with balance outstanding. The tribunal held that while payment was delayed, the assessee ultimately complied with ITSC directions. Relying on SC precedent, the tribunal noted ITSC's power to extend payment periods. Since no undisclosed income was specified during search proceedings under Section 132(4), immunity under Section 271AAA(2)(i) applied. The penalty was deleted. Case-Laws Income Tax Mon, 21 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445900