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of Penalty u/s 271B - Failure to furnish Tax audit report - Period of limitation - notice for the said year was issued only on the conclusion of the assessment u/s.147 r.w.s. 143(3) - The assessee may not have filed the return for a particular year, as infact is the case for AY 2012-2013, so that the fact of non-furnishing the audit report u/s.44AB would not come to the notice of the Revenue. It is presumably for such like reasons that the Legislature had deemed it fit not to prescribe any time limitation for the issue of the said notice. Once commenced, the proceedings though are to be concluded within prescribed time. - AT
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