rightly
imposed the penalty under Section 270A of the Act and declined the
immunity under Section 270AA of the Act.
6. This court ... which limb of Section 270A of the Act is attracted
and how the ingredient of sub-section (9) of Section
270A is satisfied
pursuant to which the applications of the
petitioner referable to Section 270AA(4) of the Income Tax Act, 19611
for being accorded immunity from imposition ... petitioner would fall within the
exclusionary provisions enshrined in sub-section (3) of Section 270AA
and thus the Court would hold that the respondent
pursuant to which the applications of the
petitioner referable to Section 270AA(4) of the Income Tax Act, 19611
for being accorded immunity from imposition ... petitioner would fall within the
exclusionary provisions enshrined in sub-section (3) of Section 270AA
and thus the Court would hold that the respondent
Section 270A of the
Income Tax Act, 1961 ['the Act'] for the Assessment Year 2017-18.
Petitioner also seeks immunity under Section 270AA ... impugned order under Section 270A of the Act is
set aside and the respondents are directed to grant immunity under Section
270AA
Section 270A of the
Income Tax Act, 1961 ['the Act'] for the assessment year 2018-19.
Petitioner also seeks immunity under Section 270AA ... impugned order under Section 270A of the Act is
set aside and the respondent is directed to grant immunity under Section
270AA
order
dated 09th March, 2022 passed by Respondent No.1 under section 270AA(4)
of the Income Tax Act, 1961 (hereinafter referred ... which limb
of Section 270A of the Act is attracted and how the ingredient of sub-section
(9) of Section 270A is satisfied
Before proceeding further, it is relevant to refer to Sub-
section 4 of Section 270AA of the Act, which reads as under:
270AA xxxx xxxx ... heard.
xxxx xxxx xxxx xxxx
13. The proviso to Sub-section(4) of Section 270AA of the
Act makes it amply clear that before
impugning the
order dated 23.09.2024 (hereafter the impugned order) passed under Section
270AA of the Income Tax Act, 1961 (hereafter the Act) rejecting the
petitioner ... petitioner for immunity from imposition of the penalty
under Section 270AA of the Act, afresh. This course commends to this
Court.
9. We, accordingly
