Penalty u/s 270A Deleted – Immunity u/s 270AA Allowed Despite Procedural Lapse: ITAT Chennai

Citadines OMR Aparthotel Pvt. Ltd Vs ITO (ITAT Chennai) Penalty U/s 270A deleted – Immunity U/s 270AA allowed despite non-filing of Form-68; procedural lapse held technical – ITAT Chennai In Citadines OMR Aparthotel Pvt. Ltd. vs ITO (A.Y. 2018-19), penalty of ₹21.30 lakh u/s 270A was levied for under-reporting of income arising from prior-period expenditure disallowed during revision u/s 263 proceedings. The assessee had accepted the disallowance, paid tax and interest, and did not file any appeal against the revised assessment. The Tribunal noted that the assessee satisfied substantive ...