https://www.taxtmi.com/caselaws?id=784495 A final immunity certificate issued under the Direct Tax Dispute Resolution Scheme, 2016 was treated as conclusive and operated as a bar against further penalty-related action under the Income-tax Act. The article states that, once immunity from penalty proceedings was granted in respect of the disputed tax, the revisional authority could not direct a de novo penalty order on the basis of an audit objection. It further notes that the immunity was general and was not defeated merely because the penalty was described under an allegedly incorrect provision. The concluded position was that reopening or revisional interference could not survive once the scheme certificate had attained finality. 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 A final immunity certificate issued under the Direct Tax Dispute Resolution Scheme, 2016 was treated as conclusive and operated as a bar against further penalty-related action under the Income-tax Act. The article states that, once immunity from penalty proceedings was granted in respect of the disputed tax, the revisional authority could not direct a de novo penalty order on the basis of an audit objection. It further notes that the immunity was general and was not defeated merely because the penalty was described under an allegedly incorrect provision. The concluded position was that reopening or revisional interference could not survive once the scheme certificate had attained finality. Case-Laws Income Tax Thu, 11 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784495