https://www.taxtmi.com/caselaws?id=798102 Penalty immunity requires an opportunity of hearing before an application can be rejected, and the rejection must identify the statutory conditions that remain unmet. Where the penalty order does not disclose non-compliance, the immunity application requires fresh consideration, including the taxpayer's compliance with prescribed conditions and any delay in filing Form No. 68. Income disclosed only in response to reassessment notice may constitute under-reported income where no original return was filed and no explanation is provided. If immunity is unavailable, penalty must be determined through a reasoned proceeding after a further hearing. en-us Mon, 31 Aug 2026 00:00:00 +0530 Wed, 02 Sep 2026 08:30:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798102 Penalty immunity requires an opportunity of hearing before an application can be rejected, and the rejection must identify the statutory conditions that remain unmet. Where the penalty order does not disclose non-compliance, the immunity application requires fresh consideration, including the taxpayer's compliance with prescribed conditions and any delay in filing Form No. 68. Income disclosed only in response to reassessment notice may constitute under-reported income where no original return was filed and no explanation is provided. If immunity is unavailable, penalty must be determined through a reasoned proceeding after a further hearing. Case-Laws Income Tax Mon, 31 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798102