Clean slate principle extinguishes uncrystallised operational claims and bars continuation of pending recovery and arbitral proceedings after plan app...
Works contract classification governs composite layout-development contracts where VAT-paid goods are transferred alongside construction and infrastru...
Specified income tax exemption for pollution control body remains conditional on non-commercial activity, unchanged income character, and return filin...
ITAT held that recording of satisfaction by the AO is a condition precedent to initiate penalty proceedings under s.271D for alleged contravention of s.269SS, and where the AO's satisfaction was embodied in the assessment order dated 30-12-2022 after statutory approval by the Addl. CIT, that date constitutes the date on which "action for imposition of penalty is considered as initiated" for purposes of s.275(1)(c). Applying the prescribed limitation, the penalty order had to be passed by 30-06-2023; the impugned penalty dated 31-08-2023 was therefore time-barred and held non est. The penalty order is quashed.
ITAT held that recording of satisfaction by the AO is a condition precedent to initiate penalty proceedings under s.271D for alleged contravention of s.269SS, and where the AO's satisfaction was embodied in the assessment order dated 30-12-2022 after statutory approval by the Addl. CIT, that date constitutes the date on which "action for imposition of penalty is considered as initiated" for purposes of s.275(1)(c). Applying the prescribed limitation, the penalty order had to be passed by 30-06-2023; the impugned penalty dated 31-08-2023 was therefore time-barred and held non est. The penalty order is quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
