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Levy of penalty u/s 271C - Period of limitation - Failure to deduct TDS - The Appellate Tribunal analyzed the facts and submissions of both parties. It was observed that the assessee had not deducted TDS as reported by the Tax Auditor, leading to a reference made by the Assessing Officer (AO) to the Joint Commissioner of Income Tax (JCIT). The Tribunal delved into the interpretation of the limitation period under Section 275(1)(c) of the Act. It considered the date of completion of quantum proceedings and the initiation of penalty proceedings. Referring to a relevant judicial precedent, the Tribunal concluded that the penalty order was indeed barred by limitation.
Levy of penalty u/s 271C - Period of limitation - Failure to deduct TDS - The Appellate Tribunal analyzed the facts and submissions of both parties. It was observed that the assessee had not deducted TDS as reported by the Tax Auditor, leading to a reference made by the Assessing Officer (AO) to the Joint Commissioner of Income Tax (JCIT). The Tribunal delved into the interpretation of the limitation period under Section 275(1)(c) of the Act. It considered the date of completion of quantum proceedings and the initiation of penalty proceedings. Referring to a relevant judicial precedent, the Tribunal concluded that the penalty order was indeed barred by limitation.
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