Inventory write-off and fraudulent/wrongful trading allegations in corporate insolvency led to director liability principles applied and appeal dismis...
Condonation of delay in filing GSTR-3B returns and entitlement to Section 62 benefit results in withdrawal of assessments and revocation of attachment...
The principal issue was whether penalty orders under section 271E (and 271D) were time-barred under section 275(1)(c). The Tribunal held that section 275(1)(c) requires either expiry of the relevant financial year after assessment or lapse of six months from the end of the month in which the Assessing Officer referred the matter for imposition of penalty; the six-month period is computed from the AO's reference, and the approval or issuance of a show-cause notice by a higher authority is irrelevant. Applying that interpretation, the penalty orders for the assessment years in question were held time-barred and the appeals were allowed. - ITAT
The principal issue was whether penalty orders under section 271E (and 271D) were time-barred under section 275(1)(c). The Tribunal held that section 275(1)(c) requires either expiry of the relevant financial year after assessment or lapse of six months from the end of the month in which the Assessing Officer referred the matter for imposition of penalty; the six-month period is computed from the AO's reference, and the approval or issuance of a show-cause notice by a higher authority is irrelevant. Applying that interpretation, the penalty orders for the assessment years in question were held time-barred and the appeals were allowed. - ITAT
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