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2002 (10) TMI 81 - KARNATAKA HIGH COURTPenalty - Concealment Of Income - penal action was initiated under section 271(1)(c) - Extension Of Period Of Limitation - it is clear that the Department has committed an error in levying penalty which is clearly barred by limitation by four days. It is also clear from the above discussion that the Explanation to section 275 cannot be invoked by the Department unilaterally to compute the period of limitation on its own without there being any request for rehearing by any assessee.
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