https://www.taxtmi.com/caselaws?id=795553 Penalty proceedings under Section 45A, despite no express limitation period, must begin within a reasonable time. The five-year periods applicable to assessment and escaped-turnover assessment provide the relevant benchmark. A show cause notice issued after that period is time-barred, and earlier communications or alleged non-cooperation do not extend the permissible period. For the relevant assessment year, proceedings had to be initiated before the applicable five-year deadline; the later notice was therefore barred by limitation and set aside. en-us Fri, 03 Jul 2026 00:00:00 +0530 Fri, 24 Jul 2026 08:36:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795553 Penalty proceedings under Section 45A, despite no express limitation period, must begin within a reasonable time. The five-year periods applicable to assessment and escaped-turnover assessment provide the relevant benchmark. A show cause notice issued after that period is time-barred, and earlier communications or alleged non-cooperation do not extend the permissible period. For the relevant assessment year, proceedings had to be initiated before the applicable five-year deadline; the later notice was therefore barred by limitation and set aside. Case-Laws VAT / Sales Tax Fri, 03 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795553