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Court Limits Revenue Authority: Notice u/s 274 Must Be Timely as Per Section 275(1)(c) for Valid Penalty.
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....Penalty u/s 271E - period of limitation as prescribed u/s 275 (1)(c) - The appellant/revenue, as noticed above, cannot extend the period of limitation by deciding at its whim and fancy when the notice has to be issued. The notice u/s 274 should have been issued before the period of limitation, as discussed above. - HC....