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    <description>Immunity from penalty under section 270AA was held to depend on fulfilment of the substantive statutory conditions, namely payment of tax and interest within the permitted time and no appeal against the assessment order. Non-filing of Form 68 within the prescribed time was treated as a procedural lapse that could not defeat the immunity where the core requirements were satisfied and the immunity application had in fact been filed. On that basis, the penalty for under-reporting of income under section 270A was found unsustainable and was directed to be deleted.</description>
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