Statutory time limit cannot be imposed through CBDT circular for compounding tax offenses.

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....No time limit prescribed u/s 279(2) of Income Tax Act for filing compounding application. CBDT circular fixing 36-month limitation period held contrary to the Act and impermissible. Judgment in Jayshree's case applied, holding CBDT cannot issue circular contrary to the object of statutory provisions. Once an offence is compoundable under the Act, right cannot be taken away by prescribing time limit through circular. Impugned order rejecting compounding application set aside.....