2022 (3) TMI 1295

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....15165- 15166/2022 - -<br>Income Tax<br>HON&#39;BLE MR. JUSTICE MANMOHAN HON&#39;BLE MR. JUSTICE DINESH KUMAR SHARMA Petitioner Through Mr.Sachit Jolly with Mr. Rohit Garg, Ms.Disha Jham, Ms.Mehak Sachdeva and Mr.Sohum Dua, Advocates.&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp; Respondents Through Mr.Sunil Agarwal, senior standing counsel with Mr. Tushar Gupta and Mr. Amarth Chaudhari, Advocates&nbsp....

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.... the Petitioner's application was rejected on the ground that the case of the Petitioner did not fall within the scope and ambit of Section 270AA of the Act. 3. Learned counsel for the Petitioner submits that the impugned order is barred by limitation in terms of Section 270AA(4) of the Act, having been passed well beyond the period of one month from the end of the month in which the Petitioner....

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....t is of the view that the Respondents' action of denying the benefit of immunity on the ground that the penalty was initiated under Section 270A of the Act for misreporting of income is not only erroneous but also arbitrary and bereft of any reason as in the penalty notice the Respondents have failed to specify the limb - "underreporting" or "misreporting" of income, under which the penalty procee....