Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
For limitation under section 275(1)(c), the relevant starting point was the date on which the AO recommended initiation of penalty proceedings to the competent authority; the Tribunal treated 11/09/2015 as that date and held that the outer time-limit expired on 31/03/2016. Because the penalty order under section 271C was passed on 19/04/2016, it was time-barred and could not be sustained. The Tribunal therefore quashed the penalty order.
For limitation under section 275(1)(c), the relevant starting point was the date on which the AO recommended initiation of penalty proceedings to the competent authority; the Tribunal treated 11/09/2015 as that date and held that the outer time-limit expired on 31/03/2016. Because the penalty order under section 271C was passed on 19/04/2016, it was time-barred and could not be sustained. The Tribunal therefore quashed the penalty order.
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