Supreme Court Upholds Penalty Imposed u/s 158BFA(2) of Income Tax Act, Overturns ITAT and High Court Decisions.

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....Penalty u/s 158BFA(2) - period of limitation - relevant date - on the issue of additions, ITAT and HC decided the matter in favor of assessee whereas Supreme Court has finally decided the matter in favor of Revenue - The notice is well within six months from the date of the order of Hon'ble Supreme Court and therefore, it cannot be gainsaid that impugned order is barred by limitation - penalty upheld....