Expanding the scope of immunity from penalty or prosecution under section 440 of the Act

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....lowing conditions, namely: - (a) the tax and interest payable as per Assessment order, has been paid within the period specified in notice of demand; (b) no appeal against the such assessment order has been filed. 2. Further, sub-section (2) provides that assessee shall file an application within one month from the end of the month in which said assessment order has been received by him. Furt....

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....n of immunity should also be extended to such cases where under-reporting of income is in consequence of misreporting. However, the taxpayer is required to pay an additional income-tax to the extent of 100% of the amount of tax payable on such income in lieu of the penalty. 5. Additionally, as the separate penalty (existing penalty under section 443 of the Act) for income determined by AO, which ....