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“immunity under section 270AA”

PenaltySection 270AASection 270AA68 judgments

SHREE SWATI TEXDYES PVT. LTD.,AHMEDABAD vs. THE DY. CIT, CIRCLE-4(1)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 2222/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad12 Mar 2026AY 2020-21

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rameshwar P Meena, Sr. DRFor Respondent: Shri Rameshwar P Meena, Sr. DR
Section 14ASection 270ASection 40

concealment or misreporting and the assessee had even withdrawn the claim of cess deduction before completion of assessment and applied for immunity under section 270AA, penalty for under-reporting and misreporting under section 270A of the Act was held to be unjustified 20. Respectfully following the aforesaid decisions on identical

MEHUL PRAVINCHANDRA SHETH ,MUMBAI vs. DCIT, C.C 1(2), MUMBAI

In the result, the appeal of the assessee bearing ITA No

ITA 4702/MUM/2025[2019-20]Status: DisposedITAT Mumbai05 Mar 2026AY 2019-20
Section 10Section 132Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 270ASection 274

filing Form No. 68.", "held": "The AO levied penalty under section 270A without passing a speaking order on the assessee's application for immunity under section 270AA. The Tribunal, relying on a coordinate bench decision, held that if the assessee complies with the conditions for immunity, the AO must grant ... 270AA(4)", "270A(9)"], "issues": "Whether the penalty levied under section 270A is sustainable when the assessee has complied with the conditions for immunity under section 270AA and the AO has not passed a speaking order on the application."}} }} ."}} the order on the immunity application

JOYDEEP MUKHERJEE,PRESENTLY RESIDING AT USA vs. DCIT, INTL TAXATION CIRCLE 1(2), BANGALORE, BMTC BUILDING, KORAMANGALA

The appeal of the assessee is allowed for statistical purposes

ITA 2017/BANG/2025[2018-19]Status: DisposedITAT Bangalore23 Feb 2026AY 2018-19

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2018-19 Joydeep Mukherjee, Vs. The Deputy Commissioner A 202, Prestige St. Johns Woods Of Income Tax Apt., 80, St. Johns Cross Road, International Taxation, Circle 1(2), Bengaluru South 560 029. Bangalore. Pan: Aawpm 7656E

For Appellant: Shri Pranav Krishna, AdvocateFor Respondent: Shri K. Saravanan, Addl.CIT(DR)(ITAT), Bengaluru
Section 139Section 144Section 147Section 148Section 270ASection 276C

dismissed. 2. The assessee is in appeal before us wherein the claim of the assessee is that the assessee has applied for immunity under section 270AA of the income tax act and despite the above fact, the penalty has been levied dismissing the claim of immunity of the assessee, without

S S R S MEM EDU SOCIETY,SOUTH EXTENSION PART-II vs. ACIT, NEW DELHI

In the result, impugned order is set aside and appeal of the assessee is\nallowed

ITA 3064/DEL/2025[2018-19]Status: DisposedITAT Delhi12 Feb 2026AY 2018-19
For Appellant: \nShri V.K Tulsian, Chartered Accountant (Virtual)For Respondent: \nShri Om Prakash, Sr. DR
Section 270A

March, 2022 passed by\nRespondent No. 1 under section 270A of the Act is quashed and Respondent No. 1 is\ndirected to grant immunity under section 270AA of the Act to the Petitioner.”\n[Emphasized by us]\nThe AO in para 3.5 of the penalty order levies penalty u/s.270A

UDAY UTTAMRAO NEVASE,PUNE vs. THE ASSESSING OFFICER / ASSESSMENT UNIT, PUNE

In the result, appeal of the assessee in ITA No

ITA 2606/PUN/2025[2022-23]Status: DisposedITAT Pune10 Feb 2026AY 2022-23

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2606/Pun/2025 निर्धारण वषा / Assessment Year: 2022-23 Uday Uttamrao Nevase, V The Assessing Officer / Saugandh Niwas, Hind Colony S Assessment Unit, Pune. Lane No.1 A, Bhekrai Nagar, Phursungi, Pune – 412308. Pan: Akqpn1150Q Appellant/ Assessee Respondent /Revenue Assessee By Ca Rohan Gupta Revenue By Shri Harshit Bari – Addl.Cit(Virtual) Date Of Hearing 16/12/2025 Date Of Pronouncement 10/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2022-23 Dated 04.09.2025 Emanating From The Penalty Order Passed Under Section 270A, Dated 17.09.2024. The Assessee Has Raised The Following Grounds Of Appeal : “Ground 1 Section 270Aa Immunity Cit A Erred In Law By Confirming The Penalty Of Rs 629382 Under Section 270A Without Considering And

Section 143(3)Section 250Section 270A

Admittedly, assessee has not filed any revised return of income. Ground No.1 : 11. Assessee has raised the ground that Assessee was eligible for immunity under section 270AA of the Act. Section 270AA is reproduced here has under : “Immunity from imposition of penalty, etc. 270AA. (1) An assessee may make

SUNIL PIYUSH SHAH,AHMEDABAD vs. NFAC, DELHI PRESENT JURIS. -THE ITO, WARD-5(3)(2), AHMEDABAD

In the result, the appeal of the assessee is dismissed

ITA 1917/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad16 Jan 2026AY 2019-20

Bench: Ms. Suchitra Kambleassessment Year 2019-20

For Appellant: Shri Sunil Piyush Shah, A.RFor Respondent: Shri Suresh Chand Meena, Sr. D.R
Section 132Section 132(4)Section 144BSection 147Section 148ASection 244ASection 250Section 270ASection 270A(9)Section 29A

allowability of the donation for deduction under section 80GGC. 6. That the initiation of penalty proceedings under section 270A and rejection of immunity under section 270AA are wholly unsustainable in law, since the reassessment order contains no finding invoking section 270A(9) or identifying circumstances of misreporting. The penalty notice

TRIJAL ENTERPRISE PRIVATE LIMITED,BHUBANESWAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2,BHUBANESWAR, BHUBANESWAR

In the result, all the appeals of the assessee are allowed

ITA 263/CTK/2025[2019-20]Status: DisposedITAT Cuttack02 Dec 2025AY 2019-20

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.261, 262 & 263/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2017-18, 2018-19 & 2019-20) Trijal Enterprise Private Limited Vs Acit, Central Circle-2, At-Hall No.6, Block-2, Bmc Bhubaneswar Bhawani Mall, Saheed Nagar, Khordha-751007, Bhubaneswar Pan No. :Aafct 9662 B (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri P.K.Mishra, Ar राजस्व की ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 02/12/2025 घोषणा की तारीख/Date Of Pronouncement : 02/12/2025 आदेश / O R D E R Per Bench : These Are The Three Appeals Filed By The Assessee Against The Separate Orders Passed By The Ld. Cit(A), Bhubaneswar-2, All Dated 25.03.2025 For The Assessment Years 2017-2018, 2018-2019 & 2019-2020 Confirming The Penalty Levy Under 270A Of The Act. 2. It Was Submitted By The Ld. Ar That For The Impugned Assessment Years The Assessee Has Filed Original Return For The Assessment Year 2017- 18 Disclosing A Loss Of Rs.8,30,930/-, For The Assessment Year 2018-19 Income Of Rs.20,46,140/- & For Assessment Year 2019-20 An Income Of Rs.17,27,850/-. There Was A Search On The Premises Of The Assessee On 03/04/2019. In Response To Notice Issued U/S.153A Of The Act, The Assessee Filed His Return Of Income For The Assessment Year 2017-18 Disclosing A Loss

For Appellant: Shri P.K.Mishra, ARFor Respondent: Shri Ashim Kumar Chakraborty, CIT-DR
Section 139Section 153ASection 270ASection 271A

dated 28th March, 2022 passed by Respondent No.1 under Section 270A of the Act is quashed and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner." 72. Further, the Hon'ble Delhi High Court in Schneider Electric South East Asia ... March, 2022 passed by Respondent No.1 under Section 270AA (4) of the Act is set aside and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner." 73. We find that the similar issue had come up for consideration before the co-ordinate bench

TRIJAL ENTERPRISE PRIVATE LIMITED,BHUBANESWAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2,BHUBANESWAR, BHUBANESWAR

In the result, all the appeals of the assessee are allowed

ITA 262/CTK/2025[2018-19]Status: DisposedITAT Cuttack02 Dec 2025AY 2018-19

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.261, 262 & 263/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2017-18, 2018-19 & 2019-20) Trijal Enterprise Private Limited Vs Acit, Central Circle-2, At-Hall No.6, Block-2, Bmc Bhubaneswar Bhawani Mall, Saheed Nagar, Khordha-751007, Bhubaneswar Pan No. :Aafct 9662 B (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri P.K.Mishra, Ar राजस्व की ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 02/12/2025 घोषणा की तारीख/Date Of Pronouncement : 02/12/2025 आदेश / O R D E R Per Bench : These Are The Three Appeals Filed By The Assessee Against The Separate Orders Passed By The Ld. Cit(A), Bhubaneswar-2, All Dated 25.03.2025 For The Assessment Years 2017-2018, 2018-2019 & 2019-2020 Confirming The Penalty Levy Under 270A Of The Act. 2. It Was Submitted By The Ld. Ar That For The Impugned Assessment Years The Assessee Has Filed Original Return For The Assessment Year 2017- 18 Disclosing A Loss Of Rs.8,30,930/-, For The Assessment Year 2018-19 Income Of Rs.20,46,140/- & For Assessment Year 2019-20 An Income Of Rs.17,27,850/-. There Was A Search On The Premises Of The Assessee On 03/04/2019. In Response To Notice Issued U/S.153A Of The Act, The Assessee Filed His Return Of Income For The Assessment Year 2017-18 Disclosing A Loss

For Appellant: Shri P.K.Mishra, ARFor Respondent: Shri Ashim Kumar Chakraborty, CIT-DR
Section 139Section 153ASection 270ASection 271A

dated 28th March, 2022 passed by Respondent No.1 under Section 270A of the Act is quashed and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner." 72. Further, the Hon'ble Delhi High Court in Schneider Electric South East Asia ... March, 2022 passed by Respondent No.1 under Section 270AA (4) of the Act is set aside and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner." 73. We find that the similar issue had come up for consideration before the co-ordinate bench

TRIJAL ENTERPRISE PRIVATE LIMITED,BHUBANESWAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, BHUBANESWAR, BHUBANESWAR

In the result, all the appeals of the assessee are allowed

ITA 261/CTK/2025[2017-18]Status: DisposedITAT Cuttack02 Dec 2025AY 2017-18

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.261, 262 & 263/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2017-18, 2018-19 & 2019-20) Trijal Enterprise Private Limited Vs Acit, Central Circle-2, At-Hall No.6, Block-2, Bmc Bhubaneswar Bhawani Mall, Saheed Nagar, Khordha-751007, Bhubaneswar Pan No. :Aafct 9662 B (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri P.K.Mishra, Ar राजस्व की ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 02/12/2025 घोषणा की तारीख/Date Of Pronouncement : 02/12/2025 आदेश / O R D E R Per Bench : These Are The Three Appeals Filed By The Assessee Against The Separate Orders Passed By The Ld. Cit(A), Bhubaneswar-2, All Dated 25.03.2025 For The Assessment Years 2017-2018, 2018-2019 & 2019-2020 Confirming The Penalty Levy Under 270A Of The Act. 2. It Was Submitted By The Ld. Ar That For The Impugned Assessment Years The Assessee Has Filed Original Return For The Assessment Year 2017- 18 Disclosing A Loss Of Rs.8,30,930/-, For The Assessment Year 2018-19 Income Of Rs.20,46,140/- & For Assessment Year 2019-20 An Income Of Rs.17,27,850/-. There Was A Search On The Premises Of The Assessee On 03/04/2019. In Response To Notice Issued U/S.153A Of The Act, The Assessee Filed His Return Of Income For The Assessment Year 2017-18 Disclosing A Loss

For Appellant: Shri P.K.Mishra, ARFor Respondent: Shri Ashim Kumar Chakraborty, CIT-DR
Section 139Section 153ASection 270ASection 271A

dated 28th March, 2022 passed by Respondent No.1 under Section 270A of the Act is quashed and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner." 72. Further, the Hon'ble Delhi High Court in Schneider Electric South East Asia ... March, 2022 passed by Respondent No.1 under Section 270AA (4) of the Act is set aside and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner." 73. We find that the similar issue had come up for consideration before the co-ordinate bench

MRINALINI JAYANT PURANIK,PUNE vs. ITO, WARD-2(2), PUNE, PUNE

In the result, the appeal filed by the assessee is allowed

ITA 1790/PUN/2025[2019-20]Status: DisposedITAT Pune28 Nov 2025AY 2019-20

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2019-20 Mrinalini Jayant Puranik Ito, Ward 2(2), Pune Flat 14, Khagol Coop Society, Vs. S.No.38/1, Panchavati, Pashan, Pune – 411008 Pan: Almpp5163E (Appellant) (Respondent) Assessee By : Shri Suhas Kulkarni Department By : Shri A D Kulkarni Date Of Hearing : 26-11-2025 Date Of Pronouncement : 28-11-2025 O R D E R Per R.K. Panda, Vp:

For Appellant: Shri Suhas KulkarniFor Respondent: Shri A D Kulkarni
Section 142(1)Section 147Section 148Section 270ASection 274

account of "under-reporting" of income. 8. Consequently, this Court is of the view that the petitioner acquired a right to be granted immunity under Section 270AA of the Act. In fact, this Court, in Schneider Electric South East Asia (HQ) Pte Ltd. Vs. Asst. Commissioner of Income Tax International ... protracted litigation". 9. Consequently, the impugned order under Section 270A of the Act is set aside and the respondent is directed to grant immunity under Section 270AA of the Act to the petitioner. 10. With the aforesaid directions, the present writ petition along with pending applications stands disposed

AJAY PAL SINGH,NOIDA GAUTOM BUDDH NAGAR vs. ITO WARD 1(1) NOIDA GBN, NOIDA

In the result, the appeal filed by the assessee is allowed

ITA 2253/DEL/2025[2020-21]Status: DisposedITAT Delhi26 Nov 2025AY 2020-21

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharmaajay Pal Singh, Vs. Ito, Ward 1 (1), Village Gadi, Near Dadri Noida. Gautam Budh Nagar - 201 301 Uttar Pradesh). (Pan : Axgps6679A) (Appellant) (Respondent) Assessee By : Shri Vijay Kumar Singla, Ca Revenue By : Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing : 02.09.2025 Date Of Order : 26.11.2025 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 12.02.2025 For The Assessment Year 2020-21. 2. Brief Facts Of The Case Are, Assessee Had Originally Filed His Return Of Income Declaring Total Income Of Rs.43,88,320/-. Subsequently, Assessee Filed Revised Return On 30.03.2021 Declaring Revised Total Income Of Rs.31,26,700/-. The Return Of Income Was Processed Under Section 143(1) Of The Income-Tax Act, 1961 (For Short ‘The Act’). Subsequently, The Case

For Appellant: Shri Vijay Kumar Singla, CAFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 143(1)Section 156Section 249Section 270ASection 270MSection 276C

portal which prevented the said application from being uploaded within time. 6 The Court highlights that the assessee is eligible for immunity under Section 270AA on satisfying three fundamental conditions: payment of tax and interest demand, and non-filing of appeal against the demand order. Moreover, the assessing officer initiated ... penalty for underreporting income and not for misreporting income. Consequently, the Petitioner acquired a right to be granted immunity under Section 270AA of the Act. After considering the submissions of the assessee, ld. CIT (A) dismissed 3. the appeal preferred by the assessee by observing as under :- “7. I have

PENNINTI VIVEKANANDA RAO,HYDERABAD vs. ADIT (INT TAXN)-2, HYDERABAD

In the result, the appeal of the assessee is allowed

ITA 1494/HYD/2025[2020-21]Status: DisposedITAT Hyderabad19 Nov 2025AY 2020-21

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1494/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2020-21) Shri Penninti Vivekananda Vs. Adit (International Rao, Hyderabad Taxation)-2 Pan:Ayupp1895L Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate H Srinivasulu राज" व "ारा/Revenue By:: Smt. U Mini Chandran, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Pronouncement: 19/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Penninti Vivekananda Rao (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-10, Hyderabad (“Ld. Cit(A)”) Dated 29.07.2025 For The A.Y 2020-21. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Advocate H SrinivasuluFor Respondent: : Smt. U Mini Chandran, CIT(DR)
Section 143(2)Section 270A

Capital Gains.” Accordingly, the Ld. AO initiated the penalty proceedings under section 270A of the Act for misreporting of income. The assessee sought immunity under section 270AA of the Act, which was rejected, and ultimately penalty of Rs.2,48,02,158/- was levied by the Ld. AO under section 270A

CHUNGATH VARGHESE SUNNY,COIMBATORE vs. DCIT, CC-3(3), CHENNAI

In the result, the appeals of the assessee in ITA Nos

ITA 1810/CHNY/2025[2021-22]Status: DisposedITAT Chennai28 Oct 2025AY 2021-22

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri. S. Sridhar, Advocate (Erode)For Respondent: Shri. Shiva Srinivas, CIT
Section 131Section 132Section 132(4)Section 143(2)Section 153CSection 270A

dated 28th March, 2022 passed by Respondent No.1 under Section 270A of the Act is quashed and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner.” 72. Further, the Hon’ble Delhi High Court in Schneider Electric South East Asia ... under Section 270AA (4) of the Act :-14-: ITA. Nos:1801 to 1810/Chny/2025 is set aside and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner.” 73. We find that the similar issue had come up for consideration before the co-ordinate bench

CHUNGATH VARGHESE SUNNY,COIMBATORE vs. DCIT, CC-3(3), CHENNAI

In the result, the appeals of the assessee in ITA Nos

ITA 1809/CHNY/2025[2020-21]Status: DisposedITAT Chennai28 Oct 2025AY 2020-21

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri. S. Sridhar, Advocate (Erode)For Respondent: Shri. Shiva Srinivas, CIT
Section 131Section 132Section 132(4)Section 143(2)Section 153CSection 270A

dated 28th March, 2022 passed by Respondent No.1 under Section 270A of the Act is quashed and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner.” 72. Further, the Hon’ble Delhi High Court in Schneider Electric South East Asia ... under Section 270AA (4) of the Act :-14-: ITA. Nos:1801 to 1810/Chny/2025 is set aside and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner.” 73. We find that the similar issue had come up for consideration before the co-ordinate bench

CHUNGATH VARGHESE SUNNY,COIMBATORE vs. DCIT, CC-3(3), CHENNAI

In the result, the appeals of the assessee in ITA Nos

ITA 1807/CHNY/2025[2018-19]Status: DisposedITAT Chennai28 Oct 2025AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri. S. Sridhar, Advocate (Erode)For Respondent: Shri. Shiva Srinivas, CIT
Section 131Section 132Section 132(4)Section 143(2)Section 153CSection 270A

dated 28th March, 2022 passed by Respondent No.1 under Section 270A of the Act is quashed and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner.” 72. Further, the Hon’ble Delhi High Court in Schneider Electric South East Asia ... under Section 270AA (4) of the Act :-14-: ITA. Nos:1801 to 1810/Chny/2025 is set aside and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner.” 73. We find that the similar issue had come up for consideration before the co-ordinate bench

CHUNGATH VARGHESE SUNNY,COIMBATORE vs. DCIT, CC-3(3), CHENNAI

In the result, the appeals of the assessee in ITA Nos

ITA 1806/CHNY/2025[2017-18]Status: DisposedITAT Chennai28 Oct 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri. S. Sridhar, Advocate (Erode)For Respondent: Shri. Shiva Srinivas, CIT
Section 131Section 132Section 132(4)Section 143(2)Section 153CSection 270A

dated 28th March, 2022 passed by Respondent No.1 under Section 270A of the Act is quashed and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner.” 72. Further, the Hon’ble Delhi High Court in Schneider Electric South East Asia ... under Section 270AA (4) of the Act :-14-: ITA. Nos:1801 to 1810/Chny/2025 is set aside and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner.” 73. We find that the similar issue had come up for consideration before the co-ordinate bench

CHUNGATH VARGHESE SUNNY,COIMBATORE vs. DCIT, CC-3(3), CHENNAI

In the result, the appeals of the assessee in ITA Nos

ITA 1805/CHNY/2025[2021-22]Status: DisposedITAT Chennai28 Oct 2025AY 2021-22

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri. S. Sridhar, Advocate (Erode)For Respondent: Shri. Shiva Srinivas, CIT
Section 131Section 132Section 132(4)Section 143(2)Section 153CSection 270A

dated 28th March, 2022 passed by Respondent No.1 under Section 270A of the Act is quashed and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner.” 72. Further, the Hon’ble Delhi High Court in Schneider Electric South East Asia ... under Section 270AA (4) of the Act :-14-: ITA. Nos:1801 to 1810/Chny/2025 is set aside and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner.” 73. We find that the similar issue had come up for consideration before the co-ordinate bench

CHUNGATH VARGHESE SUNNY,COIMBATORE vs. DCIT, CC-3(3), CHENNAI

In the result, the appeals of the assessee in ITA Nos

ITA 1804/CHNY/2025[2020-21]Status: DisposedITAT Chennai28 Oct 2025AY 2020-21

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri. S. Sridhar, Advocate (Erode)For Respondent: Shri. Shiva Srinivas, CIT
Section 131Section 132Section 132(4)Section 143(2)Section 153CSection 270A

dated 28th March, 2022 passed by Respondent No.1 under Section 270A of the Act is quashed and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner.” 72. Further, the Hon’ble Delhi High Court in Schneider Electric South East Asia ... under Section 270AA (4) of the Act :-14-: ITA. Nos:1801 to 1810/Chny/2025 is set aside and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner.” 73. We find that the similar issue had come up for consideration before the co-ordinate bench

CHUNGATH VARGHESE SUNNY,COIMBATORE vs. DCIT, CC-3(3), CHENNAI

In the result, the appeals of the assessee in ITA Nos

ITA 1803/CHNY/2025[2019-20]Status: DisposedITAT Chennai28 Oct 2025AY 2019-20

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri. S. Sridhar, Advocate (Erode)For Respondent: Shri. Shiva Srinivas, CIT
Section 131Section 132Section 132(4)Section 143(2)Section 153CSection 270A

dated 28th March, 2022 passed by Respondent No.1 under Section 270A of the Act is quashed and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner.” 72. Further, the Hon’ble Delhi High Court in Schneider Electric South East Asia ... under Section 270AA (4) of the Act :-14-: ITA. Nos:1801 to 1810/Chny/2025 is set aside and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner.” 73. We find that the similar issue had come up for consideration before the co-ordinate bench

CHUNGATH VARGHESE SUNNY,COIMBATORE vs. DCIT, CC-3(3), CHENNAI

In the result, the appeals of the assessee in ITA Nos

ITA 1801/CHNY/2025[2017-18]Status: DisposedITAT Chennai28 Oct 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri. S. Sridhar, Advocate (Erode)For Respondent: Shri. Shiva Srinivas, CIT
Section 131Section 132Section 132(4)Section 143(2)Section 153CSection 270A

dated 28th March, 2022 passed by Respondent No.1 under Section 270A of the Act is quashed and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner.” 72. Further, the Hon’ble Delhi High Court in Schneider Electric South East Asia ... under Section 270AA (4) of the Act :-14-: ITA. Nos:1801 to 1810/Chny/2025 is set aside and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner.” 73. We find that the similar issue had come up for consideration before the co-ordinate bench

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