Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
Section 80P business attribution: ITAT allows deduction on investment interest and ancillary receipts, but excludes staff-loan and other non-eligible ...
Limitation for penalty proceedings under the second limb of the penalty-limitation provision applied where no assessment proceedings had been initiated for the relevant years. On the stated facts, the penalty notice was issued independently on the basis of a statement recorded in another person's scrutiny proceedings, so the first limb, tied to completion of proceedings in which penalty action was initiated, did not apply. The limitation therefore ran for six months from the end of the month in which penalty action was initiated. The Tribunal treated the penalty orders as time-barred and quashed them, leaving the other grounds open as academic.
Limitation for penalty proceedings under the second limb of the penalty-limitation provision applied where no assessment proceedings had been initiated for the relevant years. On the stated facts, the penalty notice was issued independently on the basis of a statement recorded in another person's scrutiny proceedings, so the first limb, tied to completion of proceedings in which penalty action was initiated, did not apply. The limitation therefore ran for six months from the end of the month in which penalty action was initiated. The Tribunal treated the penalty orders as time-barred and quashed them, leaving the other grounds open as academic.
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