Preferring immunity u/s 270AA can’t restrict an assessee to challenge same issue in earlier years: C

The CBDT has clarified that where an assessee makes an application under section 270AA seeking immunity from penalty proceedings in case of under-reporting of income, Assessing Officer shall not take an adverse view in penalty proceedings under section 271(1)(c) in earlier Assessment Years just because assessee has agreed on the issue in later AY by preferring an immunity under section 270AA

from taxmann.com News https://www.taxmann.com/topstories/222330000000016390/preferring-immunity-us-270aa-can’t-restrict-an-assessee-to-challenge-same-issue-in-earlier-years-cbdt.aspx