Penalty allocation per assessment year: assess section 271(4A) applicability separately, allow year wise waiver requests; board checks aggregate threshold. Penalties under sections 271(1)(a) and 271(1)(b) are to be levied separately for each assessment year and the applicability of section 271(4A) must be considered separately with reference to the facts of each assessment year. Requests for reduction or waiver of penalty should not be rejected for all years simply because the section is inapplicable to a particular year, although for Board approval officials should consider whether aggregate penalties across years exceed the threshold for sanctioning relief.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Penalty allocation per assessment year: assess section 271(4A) applicability separately, allow year wise waiver requests; board checks aggregate threshold.
Penalties under sections 271(1)(a) and 271(1)(b) are to be levied separately for each assessment year and the applicability of section 271(4A) must be considered separately with reference to the facts of each assessment year. Requests for reduction or waiver of penalty should not be rejected for all years simply because the section is inapplicable to a particular year, although for Board approval officials should consider whether aggregate penalties across years exceed the threshold for sanctioning relief.
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