Penalty under section 271(1)(c) deleted where income was disclosed in section 153A returns and remaining additions were only estimated or computationa...
Delay and laches can defeat a request for interim protection against recovery proceedings where the party waits to approach the Court after receiving an initial notice threatening coercive action. The Court noted that the petitioner had already replied with objections to the notice, so any challenge to the proposed recovery and alleged non-consideration of the representation should have been made promptly at that stage. Because the petition was filed only after later recovery notices were issued, the delay was treated as unjustified for interim relief. Interim protection was refused, while the petition remained pending and the respondents were asked to explain the non-consideration of the representation and the timing of the recovery action.
Delay and laches can defeat a request for interim protection against recovery proceedings where the party waits to approach the Court after receiving an initial notice threatening coercive action. The Court noted that the petitioner had already replied with objections to the notice, so any challenge to the proposed recovery and alleged non-consideration of the representation should have been made promptly at that stage. Because the petition was filed only after later recovery notices were issued, the delay was treated as unjustified for interim relief. Interim protection was refused, while the petition remained pending and the respondents were asked to explain the non-consideration of the representation and the timing of the recovery action.
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