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2023 (10) TMI 1136 - AT - Income TaxPenalty u/s 271C - period of limitation - whether Notice time barred and beyond the jurisdiction of the ld. AO? - long time revenue was totally inaction and not levied the penalty - HELD THAT:- The notice u/s 274/271C was duly issued to the assessee by the ACIT, Circle-1, Jodhpur on dated 08.01.2015, the liable for imposition of penalty was duly crossed the limit by violating the provision of section 275(1)(c).The levying the penalty U/s 271C is time barred and beyond the jurisdiction of the ld. AO. We do not intervene the appeal order. The appeal order is upheld. Accordingly, the penalty U/s 271C is quashed. Decided in favour of assessee.
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