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...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
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Initiation of penalty proceedings u/s 271C and the limitation period for levying such penalty. The key points are: The penalty proceedings were initiated on the date of receipt of the reference for penalty proceedings (25.09.2014) and not on the date of issuance of the show cause notice (04.08.2014). The reference marked the first step for initiating penalty action, while the show cause notice provided an opportunity to the assessee to explain. The word 'initiated' means to begin, commence, or set in motion, as per dictionary meanings cited. The Supreme Court decision in Om Prakash Jaiswal v. D.K. Mittal was referred to for interpreting the expression 'initiate any proceedings'. Since the penalty order was passed beyond the limitation period from the date of initiation (25.09.2014), it was barred by limitation. The High Court upheld the Tribunal's decision in favor of the assessee.
Initiation of penalty proceedings u/s 271C and the limitation period for levying such penalty. The key points are: The penalty proceedings were initiated on the date of receipt of the reference for penalty proceedings (25.09.2014) and not on the date of issuance of the show cause notice (04.08.2014). The reference marked the first step for initiating penalty action, while the show cause notice provided an opportunity to the assessee to explain. The word 'initiated' means to begin, commence, or set in motion, as per dictionary meanings cited. The Supreme Court decision in Om Prakash Jaiswal v. D.K. Mittal was referred to for interpreting the expression 'initiate any proceedings'. Since the penalty order was passed beyond the limitation period from the date of initiation (25.09.2014), it was barred by limitation. The High Court upheld the Tribunal's decision in favor of the assessee.
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