Income Tax Offences: Section 278(2) and 279(2) Allow Compounding Before or After Proceedings, Not After Conviction.

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....Validity of the order 278(2) - compounding of offence u/s 279(2) - Income Tax Authorities have the power to compound the offence either before or after the institution of the proceedings but certainly not after the conviction. Clause 4 of the policy also provides that compounding of offence is not a matter of right, however, the offence may be compounded by the competent authority on satisfaction prescribed in these guidelines. - HC....