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...
For penalties for contravention of cash-receipt restrictions, proceedings commence when the Joint Commissioner, as the competent authority, issues a notice affording an opportunity of hearing; an Assessing Officer's proposal merely forwards material and does not initiate proceedings. The penalty order must be passed within six months from the end of the month of that notice. Although no express initiation period applies after receipt of the proposal, initiation should occur within a reasonable time, treated here as six months from the end of that month. Notices need not contain detailed factual particulars if the assessee receives a reasonable hearing and replies are considered. No separately recorded satisfaction by the Joint Commissioner is required before initiation.
For penalties for contravention of cash-receipt restrictions, proceedings commence when the Joint Commissioner, as the competent authority, issues a notice affording an opportunity of hearing; an Assessing Officer's proposal merely forwards material and does not initiate proceedings. The penalty order must be passed within six months from the end of the month of that notice. Although no express initiation period applies after receipt of the proposal, initiation should occur within a reasonable time, treated here as six months from the end of that month. Notices need not contain detailed factual particulars if the assessee receives a reasonable hearing and replies are considered. No separately recorded satisfaction by the Joint Commissioner is required before initiation.
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