https://www.taxtmi.com/caselaws?id=418397 The court held that the show cause notice based on a CBDT circular imposing a 12-month limitation for compounding applications was illegal. It ruled that the CBDT lacked authority to set such limitations, as they were not provided for in Section 279 of the Income Tax Act, 1961. The court deemed the circular ultra vires and directed the Income Tax Authority to consider the compounding application without regard to the circular's time restriction, emphasizing that statutory provisions prevail over administrative directives. en-us Tue, 08 Feb 2022 00:00:00 +0530 Mon, 10 Oct 2022 09:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=418397 The court held that the show cause notice based on a CBDT circular imposing a 12-month limitation for compounding applications was illegal. It ruled that the CBDT lacked authority to set such limitations, as they were not provided for in Section 279 of the Income Tax Act, 1961. The court deemed the circular ultra vires and directed the Income Tax Authority to consider the compounding application without regard to the circular's time restriction, emphasizing that statutory provisions prevail over administrative directives. Case-Laws Income Tax Tue, 08 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=418397