Opportunity to respond to jurisdictional reports is mandatory before customs settlement duty enhancement; connected applications require consistent ad...
Specific customs headings for scaffolding components prevail over general classification, invalidating misclassification proceedings and enabling with...
Liquidator appointment under Section 34 requires consideration of creditor recommendations, valid professional authorisation, and preservation of vali...
Income-tax exemption for specified regulatory fees and government grants applies subject to non-commercial activity and continuing compliance conditio...
Digital accessibility audit and remediation deadlines extended, while all other disability-compliance obligations for regulated entities remain unchan...
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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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