Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Penalty under section 271D requires the Assessing Officer to record jurisdictional satisfaction during assessment proceedings; without that satisfaction, the Joint Commissioner cannot independently initiate penalty proceedings after dropping proceedings under section 271DA, rendering the penalty without jurisdiction. The notes also explain that penalties under sections 271D and 271E remain subject to the prescribed limitation period. Where the limitation period expired before fresh proceedings were initiated, the subsequent penalty proceedings were time-barred. Accordingly, the penalties described in the source were deleted on the independent grounds of absent jurisdictional satisfaction and limitation.
Penalty under section 271D requires the Assessing Officer to record jurisdictional satisfaction during assessment proceedings; without that satisfaction, the Joint Commissioner cannot independently initiate penalty proceedings after dropping proceedings under section 271DA, rendering the penalty without jurisdiction. The notes also explain that penalties under sections 271D and 271E remain subject to the prescribed limitation period. Where the limitation period expired before fresh proceedings were initiated, the subsequent penalty proceedings were time-barred. Accordingly, the penalties described in the source were deleted on the independent grounds of absent jurisdictional satisfaction and limitation.
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