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...
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The ITAT held that penalty orders under sections 271(1)(c) and 270A for the assessment years 2014-15 to 2018-19 were barred by limitation under section 275(1)(c) of the Act. Since the penalties were imposed beyond six months from the end of the month in which penalty proceedings were initiated, such orders are illegal, void ab initio, and bad in law. Consequently, the penalties for concealment and underreporting of income were quashed. The assessee's appeal was allowed on the ground of limitation, consistent with the precedent that penalty orders passed after the prescribed limitation period are invalid.
The ITAT held that penalty orders under sections 271(1)(c) and 270A for the assessment years 2014-15 to 2018-19 were barred by limitation under section 275(1)(c) of the Act. Since the penalties were imposed beyond six months from the end of the month in which penalty proceedings were initiated, such orders are illegal, void ab initio, and bad in law. Consequently, the penalties for concealment and underreporting of income were quashed. The assessee's appeal was allowed on the ground of limitation, consistent with the precedent that penalty orders passed after the prescribed limitation period are invalid.
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