https://www.taxtmi.com/caselaws?id=441408 Interpretation of limitation for imposing penalty under income tax law: the court treated initiation of penalty proceedings as the date the departmental proposal is made, not the later issuance of a show cause notice, because allowing the latter would permit arbitrary delay by the assessing officer. Applying the statutory limitation framework and the six month outer limit from initiation, the court found proceedings initiated over eleven years after assessment (fourteen years from return filing) were time barred and ruled against revenue. en-us Thu, 27 Jul 2023 00:00:00 +0530 Wed, 11 Feb 2026 12:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=441408 Interpretation of limitation for imposing penalty under income tax law: the court treated initiation of penalty proceedings as the date the departmental proposal is made, not the later issuance of a show cause notice, because allowing the latter would permit arbitrary delay by the assessing officer. Applying the statutory limitation framework and the six month outer limit from initiation, the court found proceedings initiated over eleven years after assessment (fourteen years from return filing) were time barred and ruled against revenue. Case-Laws Income Tax Thu, 27 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=441408