Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4821 
Join Channel 
