https://www.taxtmi.com/caselaws?id=470332 Limitation for tax penalty proceedings is examined as a jurisdictional issue that may support a writ challenge to a show-cause notice without requiring exhaustion of statutory remedies. The notes explain that, even where the penalty provision contains no express limitation period, proceedings must be initiated and completed within a reasonable time. An analogous five-year period applicable to original and escaped assessments is identified as the appropriate benchmark. Departmental requests for documents or alleged non-cooperation do not extend that period where proceedings could be completed on available material. A penalty notice issued after the reasonable period is described as liable to be quashed. 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 for tax penalty proceedings is examined as a jurisdictional issue that may support a writ challenge to a show-cause notice without requiring exhaustion of statutory remedies. The notes explain that, even where the penalty provision contains no express limitation period, proceedings must be initiated and completed within a reasonable time. An analogous five-year period applicable to original and escaped assessments is identified as the appropriate benchmark. Departmental requests for documents or alleged non-cooperation do not extend that period where proceedings could be completed on available material. A penalty notice issued after the reasonable period is described as liable to be quashed. Case-Laws VAT / Sales Tax Thu, 23 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470332