https://www.taxtmi.com/caselaws?id=62450 Proper service of the penalty order and demand notice was required to start limitation; mere presence or employment at the tax office did not establish authority to accept service, so registered-post service on the assessee was treated as the effective service and the limitation objection failed. Penalty under section 221 was not sustainable because the default was only technical and venial: the assessee cooperated, provided particulars, tried to obtain payment from the non-resident principal, and ultimately ensured tax payment, without deliberate, contumacious, dishonest, or conscious disregard of the obligation. The additional attempt to proceed against the assessee as an agent without following the statutory procedure for a representative assessee was also rejected. en-us Sat, 20 May 1978 00:00:00 +0530 Wed, 19 Jan 2011 18:48:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=62450 Proper service of the penalty order and demand notice was required to start limitation; mere presence or employment at the tax office did not establish authority to accept service, so registered-post service on the assessee was treated as the effective service and the limitation objection failed. Penalty under section 221 was not sustainable because the default was only technical and venial: the assessee cooperated, provided particulars, tried to obtain payment from the non-resident principal, and ultimately ensured tax payment, without deliberate, contumacious, dishonest, or conscious disregard of the obligation. The additional attempt to proceed against the assessee as an agent without following the statutory procedure for a representative assessee was also rejected. Case-Laws Income Tax Sat, 20 May 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=62450