https://www.taxtmi.com/caselaws?id=795149 For Section 271DA penalties, initiation under Section 275(1)(c) is described as occurring when the Joint Commissioner issues a Section 274 notice, rather than when the Assessing Officer forwards a proposal. The note treats the Assessing Officer's proposal as material for the competent authority's independent consideration, without adjudicatory effect. Although no express initiation period is prescribed, it applies a reasonable-time standard of six months from the end of the month in which the proposal is received; later notice renders proceedings time-barred. It also states that detailed allegations and prior recorded satisfaction are unnecessary if the assessee receives a reasonable opportunity of hearing before penalty is imposed. en-us Tue, 07 Jul 2026 00:00:00 +0530 Fri, 17 Jul 2026 08:37:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795149 For Section 271DA penalties, initiation under Section 275(1)(c) is described as occurring when the Joint Commissioner issues a Section 274 notice, rather than when the Assessing Officer forwards a proposal. The note treats the Assessing Officer's proposal as material for the competent authority's independent consideration, without adjudicatory effect. Although no express initiation period is prescribed, it applies a reasonable-time standard of six months from the end of the month in which the proposal is received; later notice renders proceedings time-barred. It also states that detailed allegations and prior recorded satisfaction are unnecessary if the assessee receives a reasonable opportunity of hearing before penalty is imposed. Case-Laws Income Tax Tue, 07 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795149