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2023 (9) TMI 610 - ITAT RAIPURPenalty u/s. 271(1)(b) - period of limitation - failure on his part to comply with the notice issued u/s. 148 - time period contemplated in clause (a) of subsection (1) to Section 275 - HELD THAT:- As the limitation for imposing penalty u/s 271(1)(b) as per the time period contemplated in clause (a) of subsection (1) to Section 275, i.e six months from the end of the month in which appellate order was received – ITAT order dated 17,12,2014, expired on 31.07.2015, therefore, the order dated 27.07.2015 imposing the aforesaid penalty was well within the limitation period. We, thus, in terms of our aforesaid observations are unable to concur with the solitary contention advanced by the Ld. AR, i.e the penalty imposed by the A.O under Section 271(1)(b) was barred by limitation, and uphold the view taken by the lower authorities. Thus, the grounds of appeal raised by the assessee are dismissed.
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