Immunity U/s. 271AAA(2) cannot be only because entire tax, along with interest, was not paid before filing of income tax return

In our considered view, therefore, on the facts of the present case wherein entire tax and interest has been duly paid well within the time limit for payment of notice of demand under section 156 and well before the penalty proceedings were concluded, the assessee could not be denied the immunity under section 271AAA(2) only because entire tax, along with interest, was not paid before filing of income tax return or, for that purpose, before concluding the assessment proceedings.

INCOME TAX APPELLATE TRIBUNAL, KOLKATA

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