Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
The key points are regarding the penalty imposed u/s 271D read with Section 269SS, and the issue of whether the penalty orders were time-barred. The Assessing Officer made a recommendation for initiating penalty on 08/12/2017. According to Section 275(1)(c), the first condition is that the financial year in which the penalty proceedings were initiated should have expired on 31/03/2018. The second condition is that six months from the end of the month in which the action for penalty imposition was initiated should have expired on 30/06/2018. However, the Additional Commissioner of Income Tax (Appeals) initiated the penalty on 07/07/2018, despite the recommendation being made on 08/12/2017. Therefore, the penalty orders are barred by the limitation period prescribed u/s 275(1)(c) of the Income Tax Act. Consequently, the orders imposing penalty were deleted, and the decision was against the revenue authorities.
The key points are regarding the penalty imposed u/s 271D read with Section 269SS, and the issue of whether the penalty orders were time-barred. The Assessing Officer made a recommendation for initiating penalty on 08/12/2017. According to Section 275(1)(c), the first condition is that the financial year in which the penalty proceedings were initiated should have expired on 31/03/2018. The second condition is that six months from the end of the month in which the action for penalty imposition was initiated should have expired on 30/06/2018. However, the Additional Commissioner of Income Tax (Appeals) initiated the penalty on 07/07/2018, despite the recommendation being made on 08/12/2017. Therefore, the penalty orders are barred by the limitation period prescribed u/s 275(1)(c) of the Income Tax Act. Consequently, the orders imposing penalty were deleted, and the decision was against the revenue authorities.
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