Blocked input tax credit for resort construction remains unavailable; interest follows actual utilisation, while delayed payment attracts statutory pe...
Duplicate PAN allocation requires record verification and deactivation reasons before assessment-related transactions can be attributed to an assessee...
Faceless assessment safeguards require requested personal hearings and adequate final show-cause response time, failing which reassessment is required...
The ITAT allowed the appeal of the assessee, holding that the penalty order u/s 270A was barred by limitation prescribed u/s 275(1)(c). The Tribunal noted that penalty proceedings were initiated in December 2020, whether reckoned from the assessment order or from the penalty notice dated 08.12.2020. Consequently, the two possible limitation dates under s. 275(1)(c) were 31.03.2021 (end of the financial year) and 30.06.2021 (six months from the end of December 2020), with 30.06.2021 being the outer limit. As the penalty order was passed on 30.12.2021, it was held to be time-barred and without jurisdiction. The penalty was accordingly quashed, and the assessee's appeal was allowed in full.
The ITAT allowed the appeal of the assessee, holding that the penalty order u/s 270A was barred by limitation prescribed u/s 275(1)(c). The Tribunal noted that penalty proceedings were initiated in December 2020, whether reckoned from the assessment order or from the penalty notice dated 08.12.2020. Consequently, the two possible limitation dates under s. 275(1)(c) were 31.03.2021 (end of the financial year) and 30.06.2021 (six months from the end of December 2020), with 30.06.2021 being the outer limit. As the penalty order was passed on 30.12.2021, it was held to be time-barred and without jurisdiction. The penalty was accordingly quashed, and the assessee's appeal was allowed in full.
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