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    <title>2025 (3) TMI 400 - ITAT DELHI</title>
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    <description>Penalty under section 270A was discussed in the context of an assessee who had fully disclosed the receipt, later sought exemption on a bona fide legal view, and then re-offered the income in response to section 148 notice with tax and interest paid. The text states that the issue on exemption of interest on enhanced compensation was debatable, the assessee acted on a genuine understanding of law, and the reassessment was not contested. It also notes that the penalty proceedings failed because the relevant limb of section 270A(2) was not specified. On the same facts, the conditions for immunity under section 270AA were described as otherwise satisfied, and non-filing of the prescribed application was treated as not defeating substantive entitlement.</description>
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      <title>2025 (3) TMI 400 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=767015</link>
      <description>Penalty under section 270A was discussed in the context of an assessee who had fully disclosed the receipt, later sought exemption on a bona fide legal view, and then re-offered the income in response to section 148 notice with tax and interest paid. The text states that the issue on exemption of interest on enhanced compensation was debatable, the assessee acted on a genuine understanding of law, and the reassessment was not contested. It also notes that the penalty proceedings failed because the relevant limb of section 270A(2) was not specified. On the same facts, the conditions for immunity under section 270AA were described as otherwise satisfied, and non-filing of the prescribed application was treated as not defeating substantive entitlement.</description>
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