https://www.taxtmi.com/caselaws?id=772867 A statutory dispute-resolution certificate granting conclusive immunity from penalty proceedings bars reopening the same penalty matter through revision under section 263 of the Income-tax Act, 1961. The Rajasthan HC noted that the Direct Tax Dispute Resolution Scheme, 2016 treated matters covered by the certificate as final and not reopenable under the Act. Because the immunity was against institution of any penalty proceeding in relation to the disputed tax, it was not limited to a particular penalty provision. An audit-based objection that a different penalty section should have been applied could not revive a jurisdiction already barred by the scheme, so the revisional order was unsustainable. en-us Thu, 03 Apr 2025 00:00:00 +0530 Sat, 14 Jun 2025 06:47:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772867 A statutory dispute-resolution certificate granting conclusive immunity from penalty proceedings bars reopening the same penalty matter through revision under section 263 of the Income-tax Act, 1961. The Rajasthan HC noted that the Direct Tax Dispute Resolution Scheme, 2016 treated matters covered by the certificate as final and not reopenable under the Act. Because the immunity was against institution of any penalty proceeding in relation to the disputed tax, it was not limited to a particular penalty provision. An audit-based objection that a different penalty section should have been applied could not revive a jurisdiction already barred by the scheme, so the revisional order was unsustainable. Case-Laws Income Tax Thu, 03 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772867