penalty under section 270A
of the Act. Further it noted that the assessee has satisfied sub-section (1) and (2) of
section 270AA ... details as
to which limb of section 270A was attracted and how ingredient of sub-section (9) of
section 270A was satisfied, mere reference
section (4) shall be final.
(6) No appeal under section [ section 246 or] section 246A or an
application for revision under section 264 shall ... circumstances referred to in sub-
section (9) of Section 270A .
23. Sub-section (4) of Section 270AA provides that the assessing
officer shall pass
penalty under section 270A
of the Act. Further it noted that the assessee has satisfied sub-section (1) and (2) of
section 270AA ... details as
to which limb of section 270A was attracted and how ingredient of sub-section (9) of
section 270A was satisfied, mere reference
section (4) shall be final.
(6) No appeal under section [ section 246 or] section 246A or an application for
revision under section 264 shall ... circumstances referred to in sub-section (9) of Section 270A .
23. Sub-section (4) of Section 270AA provides that the assessing officer shall pass
application as
required per the mandate of Section 270AA of the Act.
6. As is discernible from the record, the assessee company had
uploaded ... issued
under Section 274 read with Section 270A of the Act dated
10.04.2021, therefore, in the absence of anything provided in
Section 270AA
section (2) of section 249 , grant immunity from imposition
of penalty under section 270Aand initiation of proceedings
under section 276C or section 276CC , where ... however the section mentioned there is section
270(9) instead of section 270(8) . The Ld.AR submitted that u/s.
270AA, sub-clause
section (2) of section 249 , grant immunity from imposition
of penalty under section 270Aand initiation of proceedings
under section 276C or section 276CC , where ... however the section mentioned there is section
270(9) instead of section 270(8) . The Ld.AR submitted that u/s.
270AA, sub-clause
section (2) of section 249 , grant
immunity from imposition of penalty under section 270A and initiation of
proceedings under section 276C or section 276CC , where ... under sub-section (4) shall be final.
(6) No appeal under section 246 or section 246A or an application for revision
under section 264 shall
immunity from penalty proceedings u/s 270A , hence order
u/s 270AA(4) cannot be passed in the case of the assessee and
immunity from ... Section 270A of the Act contemplates
penalty for under reporting and mis-reporting of income whereas
Section 270AA of the Act contemplates immunity from
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
