Eligibility for Immunity from Penalty Confirmed Despite Payment Delay u/s 271AAA Settlement Order.

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....Loss of immunity from Penalty u/s. 271AAA - Delay in payment full tax as per the order of Settlement Commission (ITSC) - DR in argument mentioned that the assessee had lost the immunity, so penalty is justified. But remained silent about the application of Section 271AAA(2)(i) - In our considered view, the assessee is eligible for granting immunity for application of penalty u/s 271AAA - AT....