https://www.taxtmi.com/caselaws?id=462944 The ITAT Guwahati held that penalty proceedings under section 158BFA(2) are independent but cannot stand if the underlying block assessment order under section 158BC is time-barred. Since the assessment orders were passed beyond the two-year limitation period prescribed under section 158BE(1)(b) from the date of the last search authorization, they were held to be nullities. Consequently, no penalty could be imposed based on such barred assessments. The Tribunal's earlier rejection of the limitation plea in quantum proceedings was noted as an error, but the ITAT clarified it lacked power to rectify that delay. The appeals were allowed, and all penalty orders under section 158BFA(2) were quashed for being founded on time-barred assessments. en-us Tue, 20 Sep 2022 00:00:00 +0530 Sat, 26 Jul 2025 08:40:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462944 The ITAT Guwahati held that penalty proceedings under section 158BFA(2) are independent but cannot stand if the underlying block assessment order under section 158BC is time-barred. Since the assessment orders were passed beyond the two-year limitation period prescribed under section 158BE(1)(b) from the date of the last search authorization, they were held to be nullities. Consequently, no penalty could be imposed based on such barred assessments. The Tribunal's earlier rejection of the limitation plea in quantum proceedings was noted as an error, but the ITAT clarified it lacked power to rectify that delay. The appeals were allowed, and all penalty orders under section 158BFA(2) were quashed for being founded on time-barred assessments. Case-Laws Income Tax Tue, 20 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462944