ITAT Denies Immunity from Penalty as Application u/s 270AA Not Filed in Prescribed Format

The ITAT (Income Tax Appellate Tribunal) denied immunity from penalty, stating that the "application under Section 270AA was not filed in the prescribed format." Section 270AA provides immunity from penalty in certain cases of under-reported income if specific conditions, including filing an application in the prescribed manner, are met. The tribunal emphasized strict adherence to procedural requirements, ruling that a technical lapse in the application format negated the assessee's eligibility for penalty immunity, despite other potential merits of their case.