Income Tax Penalty Revision Barred After Amnesty Grant for Finality of Disputes: Rajasthan HC

PCIT Vs Ram Das Maheshwai (Rajasthan High Court) The Rajasthan High Court has delivered a significant ruling clarifying that once an assessee is granted immunity under the Direct Tax Dispute Resolution Scheme, 2016 (DTDRS), the Revenue cannot reopen or revise penalty proceedings by invoking Section 263 of the Income-tax Act, 1961, even on the ground that penalty was imposed under an incorrect provision. The judgment underscores the principle that amnesty schemes are intended to bring finality and quietus to tax disputes and that statutory immunity cannot be diluted through audit objections or ...