Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
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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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