immunity from penalty cannot be denied for delay/default by Revenue

Nirman Overseas Private Limited Vs National Faceless Assessment Centre Delhi (Delhi High Court) AO issued the impugned order dated 16th March, 2022 denying the immunity from penalty and prosecuting the Petitioner on the ground that since no order under Section 270AA had been passed by the jurisdictional Assessing Officer within the statutory timeline, it may be treated as no order granting immunity to the assessee had been passed. She further states that the Respondents while denying statutory immunity to the Petitioner under Section 270AA of the Act has failed to appreciate that once the cond...