https://www.taxtmi.com/caselaws?id=471548 Section 271B penalty proceedings operate independently of assessment proceedings and require initiation within a reasonable four-year period from the relevant assessment year; initiation after about ten years rendered the earlier-year penalties time-barred. Delay in completion of the State Co-operative Department audit may constitute reasonable cause for delayed submission of the Section 44AB report, although it does not excuse non-submission after the audit is complete. For later years, a Section 142(2A) special audit fulfilled the essential purpose of the Section 44AB audit, and the audit-related delay and absence of prejudice negated penal action. en-us Tue, 08 Apr 2025 00:00:00 +0530 Tue, 08 Sep 2026 19:18:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471548 Section 271B penalty proceedings operate independently of assessment proceedings and require initiation within a reasonable four-year period from the relevant assessment year; initiation after about ten years rendered the earlier-year penalties time-barred. Delay in completion of the State Co-operative Department audit may constitute reasonable cause for delayed submission of the Section 44AB report, although it does not excuse non-submission after the audit is complete. For later years, a Section 142(2A) special audit fulfilled the essential purpose of the Section 44AB audit, and the audit-related delay and absence of prejudice negated penal action. Case-Laws Income Tax Tue, 08 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471548