Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
The case deals with the limitation period for initiating penalty proceedings u/s 271E of the Income Tax Act. It is well-established that the limitation period commences from the date of issuance of notice by the Assessing Officer, not from the subsequent notice by the Joint/Additional Commissioner. In this case, the Assessing Officer issued the penalty notice on 31/12/2010 along with the assessment order, while the Additional Commissioner issued another notice on 30/06/2011. The initial notice by the Assessing Officer remains valid and operative. Therefore, the imposition of penalty u/s 271E should have been done before 30/06/2011, not 31/12/2011. The CIT(Appeals), following judicial precedents and CBDT Circular, rightly deleted the penalty, and the Tribunal dismissed the Revenue's appeal, finding no merit.
The case deals with the limitation period for initiating penalty proceedings u/s 271E of the Income Tax Act. It is well-established that the limitation period commences from the date of issuance of notice by the Assessing Officer, not from the subsequent notice by the Joint/Additional Commissioner. In this case, the Assessing Officer issued the penalty notice on 31/12/2010 along with the assessment order, while the Additional Commissioner issued another notice on 30/06/2011. The initial notice by the Assessing Officer remains valid and operative. Therefore, the imposition of penalty u/s 271E should have been done before 30/06/2011, not 31/12/2011. The CIT(Appeals), following judicial precedents and CBDT Circular, rightly deleted the penalty, and the Tribunal dismissed the Revenue's appeal, finding no merit.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
