High Court Orders Reconsideration of Application u/s 264 for Immunity from Penalty and Proceedings.

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....Revision Petition filed u/s 264 of the order passed by AO u/s 270AA(4) - The provision does not provide for any bar or prohibition against the assessee challenging an order passed by the Assessing Officer, rejecting its application made under Sub- Section 1 of Section 270 AA. The application before Respondent No.1 was an order challenging an order of rejection passed by Respondent No. 2 of an application filed by Petitioner under Sub-Section 1 of Section 270 AA seeking grant of immunity from imposition of penalty and initiation of proceedings under Sub-Section 276( C) or Section 277 (CC). - CIT directed to consider de-novo, the application filed by Petitioner u/s 264 - HC....