Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealme...
Proceeds of crime and property equivalent in value: failure to explain lawful source sustains attachment; lack of required notice can vitiate confirma...
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Issue: Whether penalty proceedings under sections 271D and 271E were barred by limitation. The tribunal held that, applying sections 271D, 271E and 275(1) and following the Supreme Court precedent in Hissaria Brothers, the Assessing Officer's penalty orders were time-barred because they were not issued within the statutory limitation period; the appellate orders setting aside those penalties for being beyond limitation were lawful. Consequence: all four impugned penalty orders were quashed. - ITAT
Issue: Whether penalty proceedings under sections 271D and 271E were barred by limitation. The tribunal held that, applying sections 271D, 271E and 275(1) and following the Supreme Court precedent in Hissaria Brothers, the Assessing Officer's penalty orders were time-barred because they were not issued within the statutory limitation period; the appellate orders setting aside those penalties for being beyond limitation were lawful. Consequence: all four impugned penalty orders were quashed. - ITAT
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