https://www.taxtmi.com/caselaws?id=784495 Final immunity under the Direct Tax Dispute Resolution Scheme, 2016 barred revision of penalty proceedings under the Income-tax Act once the scheme certificate became conclusive. The certificate granted general immunity from penalties relating to disputed tax and could not be bypassed through a de novo penalty direction based on an audit objection. Describing the penalty as imposed under an incorrect statutory provision did not restrict or defeat that immunity. As the certificate had not been challenged and its conclusiveness precluded consideration of scheme exclusions, further penalty-related revision or reopening was barred. en-us Thu, 11 Dec 2025 00:00:00 +0530 Tue, 06 Jan 2026 08:48:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784495 Final immunity under the Direct Tax Dispute Resolution Scheme, 2016 barred revision of penalty proceedings under the Income-tax Act once the scheme certificate became conclusive. The certificate granted general immunity from penalties relating to disputed tax and could not be bypassed through a de novo penalty direction based on an audit objection. Describing the penalty as imposed under an incorrect statutory provision did not restrict or defeat that immunity. As the certificate had not been challenged and its conclusiveness precluded consideration of scheme exclusions, further penalty-related revision or reopening was barred. Case-Laws Income Tax Thu, 11 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784495