Jurisdiction Change Prompts Rehearing; 162 Days Excluded from Penalty Limitation u/ss 271E & 275 of Income Tax Act.

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....Penalty u/s 271E - Period of limitation - The assessee, on change of jurisdiction, requested for rehearing the case as provided in the proviso to section 129 of the Act vide letter dated 27-11-2003 which came to be concluded on 06-05-2004. Effectively, the time of 162 days was consumed in the rehearing of the case of the assessee. Accordingly, such time has to be excluded as per the explanation attached to section 275 of the Act which has been discussed here in above. - AT....