https://www.taxtmi.com/caselaws?id=199484 Section 28 requires the tax authority to form satisfaction about a specified default during the course of proceedings under the Act before initiating penalty action; the critical limit is the timing of that satisfaction, not the later service of notice. Where the default was detected and penalty proceedings were initiated while the authority was still seisin of the matter, a fresh notice under section 28(3) was not barred merely because assessment proceedings had ended. Earlier cancellation of the penalty order for want of hearing did not prevent fresh proceedings being taken in accordance with law. en-us Fri, 12 Dec 1958 00:00:00 +0530 Thu, 01 Mar 2018 14:52:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=199484 Section 28 requires the tax authority to form satisfaction about a specified default during the course of proceedings under the Act before initiating penalty action; the critical limit is the timing of that satisfaction, not the later service of notice. Where the default was detected and penalty proceedings were initiated while the authority was still seisin of the matter, a fresh notice under section 28(3) was not barred merely because assessment proceedings had ended. Earlier cancellation of the penalty order for want of hearing did not prevent fresh proceedings being taken in accordance with law. Case-Laws Income Tax Fri, 12 Dec 1958 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=199484