2026 (4) TMI 1127

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....Member For the Assessee : Sh. Sushi l Wadhwa, CA For the Revenue : Sh. Om Prakash, Sr. DR ORDER PER YOGESH KUMAR, U.S. JM: ITA No. 7300/Del/2025 (A.Y 2017-18) Brief facts of the case are that, an order of penalty under Section 270A of the Income Tax Act, 1961 ('Act' for short) came to be passed on 21/09/2021 for Assessment Year 2017-18 by imposing penalty of Rs. 5,07,847/....

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....ders of the Lower Authorities, sought for dismissal of the Appeal. 4. We have heard both the parties and perused the material available on record. As could be seen from the record, Assessee has filed an application in Form No. 68 under Section 270AA(2) of the Act on 30/01/2020 itself to avail benefit of immunity from penalty. As per the Assessee, no order has been passed on the said application....

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....sideration. 5. In the result, Appeal of the Assessee is partly allowed for statistical purpose. ITA No. 7301/Del/2025 (A.Y 2018-19) 6. In this case, the Assessee has filed application for immunity and the immunity under Section 270AA of the Act was granted to the Assessee. However, the Ld. A.O. proceeded to issues order of penalty under Section 270A vide order dated 21/09/2021. Considerin....