https://www.taxtmi.com/caselaws?id=470332 Limitation objections to delayed penalty show-cause notices raise jurisdictional concerns and may support writ jurisdiction where the notice is ex facie time-barred. Although Section 45A contains no express limitation period, penalty proceedings should be initiated and completed within a reasonable time. The analogous limitation period for original and escaped assessments provides the relevant benchmark. Departmental requests for documents or alleged taxpayer non-cooperation do not extend that period where proceedings can be completed on available material. A penalty notice issued after the comparable assessment limitation has expired is therefore vulnerable to being quashed as time-barred. en-us Thu, 23 Oct 2025 00:00:00 +0530 Thu, 23 Jul 2026 20:51:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470332 Limitation objections to delayed penalty show-cause notices raise jurisdictional concerns and may support writ jurisdiction where the notice is ex facie time-barred. Although Section 45A contains no express limitation period, penalty proceedings should be initiated and completed within a reasonable time. The analogous limitation period for original and escaped assessments provides the relevant benchmark. Departmental requests for documents or alleged taxpayer non-cooperation do not extend that period where proceedings can be completed on available material. A penalty notice issued after the comparable assessment limitation has expired is therefore vulnerable to being quashed as time-barred. Case-Laws VAT / Sales Tax Thu, 23 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470332