Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Penalty u/s. 271E - period of limitation - There is no dispute that the period of limitation is required to be examined as per Section 275(1)(c) - it is futile to contend that the date of initiation of proceedings is the date on which the JCIT receives intimation from the AO or the date on which the JCIT issues SCN to the Assessee - AO having initiated the penalty proceedings in assessment order dated 24.3.2016 and imposed on 27.1.2017 - bared by limitation
Penalty u/s. 271E - period of limitation - There is no dispute that the period of limitation is required to be examined as per Section 275(1)(c) - it is futile to contend that the date of initiation of proceedings is the date on which the JCIT receives intimation from the AO or the date on which the JCIT issues SCN to the Assessee - AO having initiated the penalty proceedings in assessment order dated 24.3.2016 and imposed on 27.1.2017 - bared by limitation
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