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2023 (5) TMI 360 - AT - Income TaxPenalty u/s 271D - period of limitation u/s 275 - extended period of limitation of six months - HELD THAT:- It cannot be said that the relevant assessment or other order was subjected to some appellate proceeding. Consequently, the extended period of limitation of 6 months from the availability of the appellate order, will not be available to the revenue. But otherwise also, the computation of the income has no bearing over the imposition or otherwise of the penalty provided u/s 271D and 271E of the Act. The issue involved in the present case is fully covered by the decision of HISSARIA BROTHERS, HANUMANGARH JN [2016 (8) TMI 1044 - SC ORDER] - Penalty imposed u/s 271D, under challenge, is barred by limitation u/s 275(1)(c). Hence, the same is hereby quashed. The additional ground of appeal taken by the assessee is therefore, allowed.
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