Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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The ITAT held that the penalty under section 271D was barred by limitation as it was imposed after the prescribed deadline of 28.02.2023, with the order dated 29.03.2023 being invalid. Additionally, the reopening of assessment was quashed due to improper approval under section 151, rendering the reassessment proceedings void ab initio. Consequently, penalty proceedings under section 271D could not be sustained in the absence of a valid assessment order. The Tribunal relied on precedents confirming that penalty action does not survive when the assessment itself is invalid. Therefore, the penalty levied under section 271D and the reassessment proceedings were set aside, and the appeal of the assessee was allowed.
The ITAT held that the penalty under section 271D was barred by limitation as it was imposed after the prescribed deadline of 28.02.2023, with the order dated 29.03.2023 being invalid. Additionally, the reopening of assessment was quashed due to improper approval under section 151, rendering the reassessment proceedings void ab initio. Consequently, penalty proceedings under section 271D could not be sustained in the absence of a valid assessment order. The Tribunal relied on precedents confirming that penalty action does not survive when the assessment itself is invalid. Therefore, the penalty levied under section 271D and the reassessment proceedings were set aside, and the appeal of the assessee was allowed.
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