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Issues: Whether the order levying penalty under section 14(4) was barred by limitation under section 14(4-A), and whether penalty proceedings initiated on reopening of assessment are ancillary to reassessment proceedings.
Analysis: The assessment was reopened under section 14(4) and reassessment was made, but the penalty order was passed more than four years after service of the original assessment order. Section 14(4-A) required any assessment or levy under section 14(4) to be made within four years from the date of service of the assessment or levy order. Penalty proceedings under section 14(4) were held to be part of, or at least ancillary to, the reopening proceedings and not wholly independent proceedings. The limitation applicable to reassessment therefore applied equally to the penalty order.
Conclusion: The penalty order was barred by limitation under section 14(4-A), and the challenge to it failed.
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