Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
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The ITAT held that penalty for TDS default under section 272A(2)(g) was not justified because the assessee had shown reasonable cause, bringing the case within the protection of section 273B. Although the defaults related to different periods and the appeal was not a duplicate, the merits were covered by an earlier order in the assessee's own case on similar facts for the same assessment year. Following that precedent, the Tribunal upheld deletion of the penalty and dismissed the Revenue's appeal.
The ITAT held that penalty for TDS default under section 272A(2)(g) was not justified because the assessee had shown reasonable cause, bringing the case within the protection of section 273B. Although the defaults related to different periods and the appeal was not a duplicate, the merits were covered by an earlier order in the assessee's own case on similar facts for the same assessment year. Following that precedent, the Tribunal upheld deletion of the penalty and dismissed the Revenue's appeal.
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