Penalty procedure under income tax law aligned with assessment and reassessment orders through show cause notice and deemed approval. Section 274 of the Income-tax Act is amended to require that the reasonable opportunity of being heard for penalty proceedings be given by way of a show cause notice. For draft assessment orders under section 144C and assessment or reassessment orders under sections 143 and 147 made on or after 1 April 2027 in relation to assessment year 2026-2027 or earlier years, penalty under section 270A is to form part of the draft assessment or assessment or reassessment order, and the Joint Commissioner's approval for such an order is deemed to include approval for the penalty.
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Provisions expressly mentioned in the judgment/order text.
Penalty procedure under income tax law aligned with assessment and reassessment orders through show cause notice and deemed approval.
Section 274 of the Income-tax Act is amended to require that the reasonable opportunity of being heard for penalty proceedings be given by way of a show cause notice. For draft assessment orders under section 144C and assessment or reassessment orders under sections 143 and 147 made on or after 1 April 2027 in relation to assessment year 2026-2027 or earlier years, penalty under section 270A is to form part of the draft assessment or assessment or reassessment order, and the Joint Commissioner's approval for such an order is deemed to include approval for the penalty.
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