← All Phrases

“immunity under section 270AA”

PenaltySection 270AASection 270AA68 judgments

The decision most relied on for immunity under section 270AA is PCIT v. Sahara India Life Insurance Co. Ltd. (432 ITR 84), cited in 185 judgments on BharatTax.

Leading authorities on immunity under section 270AA

PCIT v. Sahara India Life Insurance Co. Ltd.
432 ITR 84 · 2021 · High Court
185
citing judgments

The Assessing Officer's failure to specify the exact limb (i.e., concealment of income or furnishing inaccurate particulars) in the show-cause notice issued under Section 274 for penalty under Section 271(1)(c) vitiates the entire penalty proceedings.

Company Limited 432 ITR 84 (Del); 4. Schneider Electric South East Asia (HQ) Pte. Ltd. v. ACIT
145 Taxmann.com 665 · 2022 · High Court
13
citing judgments

Immunity from penalty under Section 270AA may be granted if the assessment order is silent on how the ingredients of Section 270A(9) are satisfied, and the penalty notice fails to specify whether the penalty is for 'under-reporting' or 'misreporting' of income.

GR Infraprojects Ltd. v. ACIT
158 Taxmann.com 80 · 2024 · High Court
11
citing judgments

Penalty under section 270A cannot be sustained without the Assessing Officer specifying the exact charge against the assessee, including which part of section 270A(9) is attracted. Immunity under section 270AA may be granted if the Assessing Officer fails to specify the relevant sub-clause of section 270A(9) or mechanically passes an order without considering the assessee's replies.

Judgments citing immunity under section 270AA

Sangam Almirah Private Limited, Muzaffarpur vs. NFAC, Delhi

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

ITA 338/PAT/2025[2018-19]Status: DisposedITAT Patna27 Oct 2025AY 2018-19

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 250Section 270ASection 270A(9)

account of EPF which was accepted by the assessee as it did not file the appeal and the assessee had requested for immunity under section 270AA of the Act. The penalty proceeding was initiated on 29/12/2020 and the application for immunity was filed on Form No. 68 on 22/01/2021

N. Vijay Kumar, ACIT, Chennai vs. Rajah Muthiah Chettiar Charitable and Educational Trust, Chennai

In the result, appeals filed by the Revenue & CO of assessee are

ITA 2097/CHNY/2025[2019-20]Status: DisposedITAT Chennai24 Oct 2025AY 2019-20

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr. Arjunraj, AdvocateFor Respondent: Mr. Saujanya Ranjan, IRS
Section 270ASection 270A(9)Section 9

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.” 7. This Court is of the opinion that the only addition in the assessment order framed ... 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. 18. At this stage, it is relevant to consider the decision of Hon’ble Madras High Court

Pankaj Kumar, Muzaffarpur vs. Commissioner of Income Tax, Patna

In the result, all the four appeals of the assessee are allowed for statistical purposes

ITA 650/PAT/2024[2020-21]Status: DisposedITAT Patna21 Oct 2025AY 2020-21

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.649, 645, 646 & 650/Pat/2024 Assessment Years: 2017–18, 2018–19, 2019–20 & 2020–21 Pankaj Kumar……..……………..………. …………………....Appellant Saraiyaganj, Muzaffarpur, Bihar-842001.. [Pan: Alipk3534A] Vs. Cit Patna……………......…..……………..………………….…..... Respondent Appearances By: Shri Amit Kamalia, Ca., Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 16, 2025 Date Of Pronouncing The Order : October 21, 2025 आदेश / Order Per Sonjoy Sarma: These Four Captioned Appeals—Ita No. 649/Patna/2024 For A.Y. 2017–18, Ita No. 645/Patna/2024 For A.Y. 2018–19, Ita No. 646/Patna/2024 For A.Y. 2019–20 & Ita No. 650/Patna/2024 For A.Y. 2020–21—Are Filed By The Same Assessee Against The Orders Of The Learned Cit(A), Relating To Penalty Imposed Under Section 270A Of The Income-Tax Act, 1961, Arising Out Of The Respective Assessment Orders. Since The Issues Involved In All These Appeals Are Common Except For Variation In Figures & Assessment Years, They Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience. 2. At The Outset, It Is Noticed That There Is A Delay Of Four Days In Filing The Appeals Before The Tribunal. The Assessee Has Filed A Petition

Section 132Section 143(3)Section 153ASection 270A

proceedings under Section 270A of the Act. The assessee, in response to the show-cause notice, filed a reply and also requested for immunity under Section 270AA from imposition of penalty. However, the Assessing Officer rejected the application and imposed a penalty of ₹15,838 under Section 270A ... being heard to the assessee. It was also contended that the assessee had duly filed an application before the Assessing Officer seeking immunity under Section 270AA, which was not properly considered. Therefore, the matter requires reconsideration by the CIT(A). 6. The learned D.R., on the other hand, supported

Pankaj Kumar, Muzaffarpur vs. Comissioner of Income Tax, Patna

In the result, all the four appeals of the assessee are allowed for statistical purposes

ITA 649/PAT/2024[2017-18]Status: DisposedITAT Patna21 Oct 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.649, 645, 646 & 650/Pat/2024 Assessment Years: 2017–18, 2018–19, 2019–20 & 2020–21 Pankaj Kumar……..……………..………. …………………....Appellant Saraiyaganj, Muzaffarpur, Bihar-842001.. [Pan: Alipk3534A] Vs. Cit Patna……………......…..……………..………………….…..... Respondent Appearances By: Shri Amit Kamalia, Ca., Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 16, 2025 Date Of Pronouncing The Order : October 21, 2025 आदेश / Order Per Sonjoy Sarma: These Four Captioned Appeals—Ita No. 649/Patna/2024 For A.Y. 2017–18, Ita No. 645/Patna/2024 For A.Y. 2018–19, Ita No. 646/Patna/2024 For A.Y. 2019–20 & Ita No. 650/Patna/2024 For A.Y. 2020–21—Are Filed By The Same Assessee Against The Orders Of The Learned Cit(A), Relating To Penalty Imposed Under Section 270A Of The Income-Tax Act, 1961, Arising Out Of The Respective Assessment Orders. Since The Issues Involved In All These Appeals Are Common Except For Variation In Figures & Assessment Years, They Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience. 2. At The Outset, It Is Noticed That There Is A Delay Of Four Days In Filing The Appeals Before The Tribunal. The Assessee Has Filed A Petition

Section 132Section 143(3)Section 153ASection 270A

proceedings under Section 270A of the Act. The assessee, in response to the show-cause notice, filed a reply and also requested for immunity under Section 270AA from imposition of penalty. However, the Assessing Officer rejected the application and imposed a penalty of ₹15,838 under Section 270A ... being heard to the assessee. It was also contended that the assessee had duly filed an application before the Assessing Officer seeking immunity under Section 270AA, which was not properly considered. Therefore, the matter requires reconsideration by the CIT(A). 6. The learned D.R., on the other hand, supported

Pankaj Kumar, Muzaffarpur vs. Commissioner of Income Tax, Patna

In the result, all the four appeals of the assessee are allowed for statistical purposes

ITA 646/PAT/2024[2019-20]Status: DisposedITAT Patna21 Oct 2025AY 2019-20

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraι.Τ.Α. Nos.649, 645, 646 & 650/Pat/2024

Section 132Section 143(3)Section 153ASection 270A

proceedings under Section 270A of the Act. The assessee, in response to the show-cause notice, filed a reply and also requested for immunity under Section 270AA from imposition of penalty. However, the Assessing Officer rejected the application and imposed a penalty of ₹15,838 under Section 270A ... being heard to the assessee. It was also contended that the assessee had duly filed an application before the Assessing Officer seeking immunity under Section 270AA, which was not properly considered. Therefore, the matter requires reconsideration by the CIT(A). 6. The learned D.R., on the other hand, supported

Pankaj Kumar, Muzaffarpur vs. Commissioner of Income Tax, Patna

In the result, all the four appeals of the assessee are allowed for statistical purposes

ITA 645/PAT/2024[2018-19]Status: DisposedITAT Patna21 Oct 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.649, 645, 646 & 650/Pat/2024 Assessment Years: 2017–18, 2018–19, 2019–20 & 2020–21 Pankaj Kumar……..……………..………. …………………....Appellant Saraiyaganj, Muzaffarpur, Bihar-842001.. [Pan: Alipk3534A] Vs. Cit Patna……………......…..……………..………………….…..... Respondent Appearances By: Shri Amit Kamalia, Ca., Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 16, 2025 Date Of Pronouncing The Order : October 21, 2025 आदेश / Order Per Sonjoy Sarma: These Four Captioned Appeals—Ita No. 649/Patna/2024 For A.Y. 2017–18, Ita No. 645/Patna/2024 For A.Y. 2018–19, Ita No. 646/Patna/2024 For A.Y. 2019–20 & Ita No. 650/Patna/2024 For A.Y. 2020–21—Are Filed By The Same Assessee Against The Orders Of The Learned Cit(A), Relating To Penalty Imposed Under Section 270A Of The Income-Tax Act, 1961, Arising Out Of The Respective Assessment Orders. Since The Issues Involved In All These Appeals Are Common Except For Variation In Figures & Assessment Years, They Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience. 2. At The Outset, It Is Noticed That There Is A Delay Of Four Days In Filing The Appeals Before The Tribunal. The Assessee Has Filed A Petition

Section 132Section 143(3)Section 153ASection 270A

proceedings under Section 270A of the Act. The assessee, in response to the show-cause notice, filed a reply and also requested for immunity under Section 270AA from imposition of penalty. However, the Assessing Officer rejected the application and imposed a penalty of ₹15,838 under Section 270A ... being heard to the assessee. It was also contended that the assessee had duly filed an application before the Assessing Officer seeking immunity under Section 270AA, which was not properly considered. Therefore, the matter requires reconsideration by the CIT(A). 6. The learned D.R., on the other hand, supported

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Tiruvannamalai

In the result, all the six appeals of the Revenue are

ITA 1655/CHNY/2025[2021-22]Status: DisposedITAT Chennai21 Oct 2025AY 2021-22

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

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

misreporting’ of income, under which penalty proceedings had been initiated, penalty notice was erroneous and arbitrary and, thus, petitioner was to be granted immunity under section 270AA 6.5.7 The undersigned upon examination of the various decisions relied upon supra, the decision of the jurisdictional tribunal in the case of Enrica ... 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

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Thiruvannamalai

In the result, all the six appeals of the Revenue are

ITA 1654/CHNY/2025[2020-21]Status: DisposedITAT Chennai21 Oct 2025AY 2020-21

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

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

misreporting’ of income, under which penalty proceedings had been initiated, penalty notice was erroneous and arbitrary and, thus, petitioner was to be granted immunity under section 270AA 6.5.7 The undersigned upon examination of the various decisions relied upon supra, the decision of the jurisdictional tribunal in the case of Enrica ... 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

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Thiruvannamalai

In the result, all the six appeals of the Revenue are

ITA 1653/CHNY/2025[2019-20]Status: DisposedITAT Chennai21 Oct 2025AY 2019-20

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

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

misreporting’ of income, under which penalty proceedings had been initiated, penalty notice was erroneous and arbitrary and, thus, petitioner was to be granted immunity under section 270AA 6.5.7 The undersigned upon examination of the various decisions relied upon supra, the decision of the jurisdictional tribunal in the case of Enrica ... 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

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Tiruvannamalai

In the result, all the six appeals of the Revenue are

ITA 1652/CHNY/2025[2018-19]Status: DisposedITAT Chennai21 Oct 2025AY 2018-19

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

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

misreporting’ of income, under which penalty proceedings had been initiated, penalty notice was erroneous and arbitrary and, thus, petitioner was to be granted immunity under section 270AA 6.5.7 The undersigned upon examination of the various decisions relied upon supra, the decision of the jurisdictional tribunal in the case of Enrica ... 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

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Tiruvannamalai

In the result, all the six appeals of the Revenue are

ITA 1651/CHNY/2025[2017-18]Status: DisposedITAT Chennai21 Oct 2025AY 2017-18

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

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

misreporting’ of income, under which penalty proceedings had been initiated, penalty notice was erroneous and arbitrary and, thus, petitioner was to be granted immunity under section 270AA 6.5.7 The undersigned upon examination of the various decisions relied upon supra, the decision of the jurisdictional tribunal in the case of Enrica ... 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

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Chennai

In the result, all the six appeals of the Revenue are

ITA 1650/CHNY/2025[2015-16]Status: DisposedITAT Chennai21 Oct 2025AY 2015-16

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

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

misreporting’ of income, under which penalty proceedings had been initiated, penalty notice was erroneous and arbitrary and, thus, petitioner was to be granted immunity under section 270AA 6.5.7 The undersigned upon examination of the various decisions relied upon supra, the decision of the jurisdictional tribunal in the case of Enrica ... 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

M/S Himalayan Vacations, P. Ltd., Nanital vs. ACIT, Haldwani

In the result, the appeal of the assessee is allowed

ITA 43/DDN/2025[2018-19]Status: DisposedITAT Dehradun26 Sept 2025AY 2018-19

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalm/S Himalayan Vacations Private Acit, Limited, Circle-2(1)(1), 01, Himalayan Vacations Private Vs. Haldawani. Limited, Tallital, Nainital-263002. Pan:Aacch5584P (Appellant) (Respondent) Assessee By Shri Pavan Kumar Nath, Adv. Department By Shri Amar Pal Singh, Sr. Dr

Section 250Section 270Section 270ASection 270A(9)Section 270A(9)(a)Section 274Section 9

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. 11. With the aforesaid directions, the present writ petition along with pending applications stand disposed

Chundayil Kalam Girijadevi, Keralassery vs. ITO Ward 1 & Tps, Palakkad

ITA 564/COCH/2025[2018-19]Status: DisposedITAT Cochin22 Sept 2025AY 2018-19

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Padmnathan K.VFor Respondent: Smt. Leena Lal
Section 250Section 270ASection 271(1)(c)Section 4

Assuming but not admitting, penalty under section 270A can be imposed for under-reporting in the present case, the appellant is entitled to immunity under section 270AA since the entire tax stands already paid and no appeal has been filed against the assessment order. J. The appellant craves to reserve ... erred in concluding that Assessee had misreported income; and (b) even if the Assessee is held to have underreported income, the benefit of immunity under Section 270AA of the Act should be extended to the Assessee since the Assessee had paid additional tax demand and had not filed appeal against

Vinod Jindal, Faridabad, Haryana vs. DCIT, Central Circle-2, Faridabad, Haryana

In the result, appeals of the assessee are allowed

ITA 1923/DEL/2025[2017-18]Status: DisposedITAT Delhi12 Sept 2025AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1918, 1919, 1920, 1921 & 1923/Del/2025 िनधा"रणवष"/Assessment Years:2013-14 To 2017-18 बनाम Shri Vinod Jindal, Dcit, H.No.1203A, Tower C-3, Vs. Central Circle-2, Srs Pearl Heights, Faridabad. Sector-87, Faridabad. Pan No.Aenpj1202Q अपीलाथ" Appellant ""यथ"/Respondent

Section 250Section 270ASection 271Section 271(1)(c)Section 274

Respondents. He relies on the impugned order dated 09th March, 2022 to contend that the Petitioner is not entitled to the benefit of immunity under Section 270AA of the Act. 6. Having perused the impugned order dated 09th March, 2022, this Court is of the view that the Respondents’ action ... 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.” 11. We also observed that the Mumbai Bench of the Tribunal in the case of Manish Manohardas

Vinod Jindal, Faridabad, Haryana vs. DCIT, Central Circle-2, Faridabad, Haryana

In the result, appeals of the assessee are allowed

ITA 1921/DEL/2025[2016-17]Status: DisposedITAT Delhi12 Sept 2025AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1918, 1919, 1920, 1921 & 1923/Del/2025 िनधा"रणवष"/Assessment Years:2013-14 To 2017-18 बनाम Shri Vinod Jindal, Dcit, H.No.1203A, Tower C-3, Vs. Central Circle-2, Srs Pearl Heights, Faridabad. Sector-87, Faridabad. Pan No.Aenpj1202Q अपीलाथ" Appellant ""यथ"/Respondent

Section 250Section 270ASection 271Section 271(1)(c)Section 274

Respondents. He relies on the impugned order dated 09th March, 2022 to contend that the Petitioner is not entitled to the benefit of immunity under Section 270AA of the Act. 6. Having perused the impugned order dated 09th March, 2022, this Court is of the view that the Respondents’ action ... 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.” 11. We also observed that the Mumbai Bench of the Tribunal in the case of Manish Manohardas

Vinod Jindal, Faridabad, Haryana vs. DCIT, Central Circle-2, Faridabad, Haryana

In the result, appeals of the assessee are allowed

ITA 1920/DEL/2025[2015-16]Status: DisposedITAT Delhi12 Sept 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1918, 1919, 1920, 1921 & 1923/Del/2025 िनधा"रणवष"/Assessment Years:2013-14 To 2017-18 बनाम Shri Vinod Jindal, Dcit, H.No.1203A, Tower C-3, Vs. Central Circle-2, Srs Pearl Heights, Faridabad. Sector-87, Faridabad. Pan No.Aenpj1202Q अपीलाथ" Appellant ""यथ"/Respondent

Section 250Section 270ASection 271Section 271(1)(c)Section 274

Respondents. He relies on the impugned order dated 09th March, 2022 to contend that the Petitioner is not entitled to the benefit of immunity under Section 270AA of the Act. 6. Having perused the impugned order dated 09th March, 2022, this Court is of the view that the Respondents’ action ... 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.” 11. We also observed that the Mumbai Bench of the Tribunal in the case of Manish Manohardas

Vinod Jindal, Faridabad, Haryana vs. DCIT, Central Circle-2, Faridabad, Haryana

In the result, appeals of the assessee are allowed

ITA 1919/DEL/2025[2014-15]Status: DisposedITAT Delhi12 Sept 2025AY 2014-15

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1918, 1919, 1920, 1921 & 1923/Del/2025 िनधा"रणवष"/Assessment Years:2013-14 To 2017-18 बनाम Shri Vinod Jindal, Dcit, H.No.1203A, Tower C-3, Vs. Central Circle-2, Srs Pearl Heights, Faridabad. Sector-87, Faridabad. Pan No.Aenpj1202Q अपीलाथ" Appellant ""यथ"/Respondent

Section 250Section 270ASection 271Section 271(1)(c)Section 274

Respondents. He relies on the impugned order dated 09th March, 2022 to contend that the Petitioner is not entitled to the benefit of immunity under Section 270AA of the Act. 6. Having perused the impugned order dated 09th March, 2022, this Court is of the view that the Respondents’ action ... 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.” 11. We also observed that the Mumbai Bench of the Tribunal in the case of Manish Manohardas

Vinod Jindal, Faridabad, Haryana vs. DCIT, Central Circle-2, Faridabad, Haryana

In the result, appeals of the assessee are allowed

ITA 1918/DEL/2025[2013-14]Status: DisposedITAT Delhi12 Sept 2025AY 2013-14

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1918, 1919, 1920, 1921 & 1923/Del/2025 िनधा"रणवष"/Assessment Years:2013-14 To 2017-18 बनाम Shri Vinod Jindal, Dcit, H.No.1203A, Tower C-3, Vs. Central Circle-2, Srs Pearl Heights, Faridabad. Sector-87, Faridabad. Pan No.Aenpj1202Q अपीलाथ" Appellant ""यथ"/Respondent

Section 250Section 270ASection 271Section 271(1)(c)Section 274

Respondents. He relies on the impugned order dated 09th March, 2022 to contend that the Petitioner is not entitled to the benefit of immunity under Section 270AA of the Act. 6. Having perused the impugned order dated 09th March, 2022, this Court is of the view that the Respondents’ action ... 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.” 11. We also observed that the Mumbai Bench of the Tribunal in the case of Manish Manohardas

Arusuvai Food Processors Pvt. Ltd., Salem vs. DCIT, Circle-1(1), Salem

In the result, appeal filed by the assessee is allowed

ITA 416/CHNY/2025[2017-18]Status: DisposedITAT Chennai28 Aug 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr.D. Anand, Advocate
Section 133(6)Section 142(1)Section 143(3)Section 264Section 270ASection 270A(1)Section 270A(9)(a)Section 270A(9)(c)Section 271Section 41(1)

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.” 7. This Court is of the opinion that the only addition in the assessment order framed ... 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. 18. At this stage, it is relevant to consider the decision of Hon’ble Madras High Court