Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
In a penalty matter under section 271D, the ITAT held that limitation under section 275(1)(c) runs from the Assessing Officer's reference initiating penalty action, not from the later notice issued by the Additional Commissioner. After noting conflicting High Court views, it followed the later Karnataka High Court position and also applied the principle that, where two non-jurisdictional interpretations are possible, the one favourable to the assessee must be adopted. As the penalty order was passed beyond the permissible period from the date of initiation, the penalty was time-barred and was quashed.
In a penalty matter under section 271D, the ITAT held that limitation under section 275(1)(c) runs from the Assessing Officer's reference initiating penalty action, not from the later notice issued by the Additional Commissioner. After noting conflicting High Court views, it followed the later Karnataka High Court position and also applied the principle that, where two non-jurisdictional interpretations are possible, the one favourable to the assessee must be adopted. As the penalty order was passed beyond the permissible period from the date of initiation, the penalty was time-barred and was quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4816 
Join Channel 
