The assessee had not filed the ITR for the AY.2019-20 either u/s 139 or in response to notice u/s 148. In the assessment major addition of Rs.58,00,000/- was made under 69A and penalty u/s 271AAC was levied on it. In addition to this bank interest of Rs.12,000/- was added and penalty notice  u/s 270A issued twards under reporting of income. In such cases what is the under reporting income , whether it is Rs.58,12,000/- or Rs.12,000/- . If it is Rs.58,12,000/- the penalty u/s 271AAC was already charged on Rs.58,00,000/- and charging again u/s 270A is not tenable, because the assessee gets immunity on such income u/s 270AA(2) of the IT Act. Then how to calculate tax on under reporting income of Rs.12,000/- ?

Q2. The disallowance of deductions claimed u/s 54 and 80P on technical reasons of delay in filing the ITR etc in the assesssment and arriving under reporting of income thereon gets any immunity from levying penalty u/s 270A?