https://www.taxtmi.com/caselaws?id=761520 Whether penalty proceedings under the tax statute were time barred turned on when such proceedings were "initiated." The court construed "initiated" by ordinary dictionary meaning as the first introductory step and held that the assessing officer's reference to the penalty authority constituted commencement of penalty action. Issuance of a subsequent show cause notice was a procedural step to afford opportunity but did not mark initiation. Applying that test, the court found the penalty proceedings began on the date of the reference and that the later penalty order was barred by limitation; decision adverse to revenue. en-us Wed, 06 Nov 2024 00:00:00 +0530 Tue, 12 May 2026 11:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761520 Whether penalty proceedings under the tax statute were time barred turned on when such proceedings were "initiated." The court construed "initiated" by ordinary dictionary meaning as the first introductory step and held that the assessing officer's reference to the penalty authority constituted commencement of penalty action. Issuance of a subsequent show cause notice was a procedural step to afford opportunity but did not mark initiation. Applying that test, the court found the penalty proceedings began on the date of the reference and that the later penalty order was barred by limitation; decision adverse to revenue. Case-Laws Income Tax Wed, 06 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761520