https://www.taxtmi.com/caselaws?id=148381 Where a penalty provision is expressly linked to a best judgment assessment, the limitation period for making that assessment also governs the initiation of the connected penalty proceedings. Section 14(1) required the assessment to be made within four years from the end of the relevant year, and section 14(2) allowed penalty only in the course of that assessment framework. The notice-and-inquiry requirement in the proviso did not break the statutory connection between assessment and penalty. Accordingly, penalty proceedings started after expiry of the four-year period were invalid. en-us Thu, 18 Apr 1968 00:00:00 +0530 Fri, 26 Apr 2013 13:13:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=148381 Where a penalty provision is expressly linked to a best judgment assessment, the limitation period for making that assessment also governs the initiation of the connected penalty proceedings. Section 14(1) required the assessment to be made within four years from the end of the relevant year, and section 14(2) allowed penalty only in the course of that assessment framework. The notice-and-inquiry requirement in the proviso did not break the statutory connection between assessment and penalty. Accordingly, penalty proceedings started after expiry of the four-year period were invalid. Case-Laws VAT and Sales Tax Thu, 18 Apr 1968 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=148381