Need valuable suggestion on ITBA/PNL/F/270AA notice received for the SECOND time

Sir/ Madam,
With reference to the application filed by you in Form No. 68 under Section 270AA(2) of the Income-tax Act, 1961 on 04.05.2026 seeking immunity from penalty proceedings initiated under Section 274 read with Section 270A of the Income-tax Act, 1961 for A.Y.

2024-25, it is observed as under:

1. As per the provisions of Section 270AA(2) of the Income-tax Act, 1961, an application for immunity is required to be made within one month from the end of the month in which the order of assessment or reassessment under Section 143(3) or Section 147, as the case may be, is received by the assessee.
   In your case, the assessment order under Section 143(3) read with Section 144B of the Income-tax Act, 1961 was passed on 19.03.2026. However, the application in Form No. 68 was filed on 04.05.2026, which appears to be beyond the prescribed time limit and therefore does not satisfy the condition laid down under Section 270AA(2) of the Act.

2.Further, as per the provisions of Section 270AA(3) of the Income-tax Act, 1961, immunity from penalty under Section 270A may be granted only in cases where penalty proceedings have not been initiated under the circumstances referred to in Section 270A(9) of the Act.

In view of the above facts, it appears that the application filed by you under Section 270AA of the Income-tax Act, 1961 is not maintainable and is liable to be rejected.

Received the above notice even after giving the response for the first notice and they rejected form 68 (we filed as per the timeline) and also paid the Demand amount raised by AO within the deadline.