https://www.taxtmi.com/caselaws?id=769440 The ITAT Pune upheld CIT(A)'s order cancelling penalty u/s 271(1)(c) on multiple grounds. The tribunal held that penalty was not warranted for notional rental income from vacant property, arithmetical errors in rental income disclosure, and buffer income voluntarily disclosed before Settlement Commission. Regarding salary income, penalty was deleted as HC admitted substantial question of law on residential status issue. Most significantly, the tribunal found penalty proceedings were barred by limitation, calculating that immunity period of 20 months granted by Settlement Commission must be added to statutory limitation periods, making the penalty order dated 26.09.2018 time-barred under both limitation tests. en-us Mon, 21 Apr 2025 00:00:00 +0530 Fri, 25 Apr 2025 08:53:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769440 The ITAT Pune upheld CIT(A)'s order cancelling penalty u/s 271(1)(c) on multiple grounds. The tribunal held that penalty was not warranted for notional rental income from vacant property, arithmetical errors in rental income disclosure, and buffer income voluntarily disclosed before Settlement Commission. Regarding salary income, penalty was deleted as HC admitted substantial question of law on residential status issue. Most significantly, the tribunal found penalty proceedings were barred by limitation, calculating that immunity period of 20 months granted by Settlement Commission must be added to statutory limitation periods, making the penalty order dated 26.09.2018 time-barred under both limitation tests. Case-Laws Income Tax Mon, 21 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769440