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The Income-tax Officer, Ward 17 (4) , New Delhi Versus M/s Vishu Impex Pvt. Ltd.

Penalty u/ss 271D and 271E - whether penalty orders alleging that the same are barred by limitation as prescribed u/s 275(1)(c)? - Held that:- The limitation as prescribed u/s 271(1)(c) has to be reckoned from the date of first notice issued by the AO, though not competent to impose penalty on 31.12.2009 and thus penalty order has to be passed on or before 30.6.2010 and penalty order passed after more than six months on 4.1.2011 u/s 271D and 271E of the Act are clearly hit by the limitation peri .....

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e Respondent : DR ORDER Per Chandra Mohan Garg, Judicial Member The above captioned appeals by the Revenue have been filed against the order of the ld. CIT(A)-XIV, New Delhi dated 7.4.2011 and 13.5.2011 passed in Appeal Nos. 267 & 268/2010-11 for A.Y 2007-08 by which penalty levied by the AO u/ss 271D & 271E of the Income-tax Act, 1961 ['the Act' for short] have been cancelled allowing the appeals of the assessee. 2. The assessee has also filed cross objections challenging the va .....

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d for admission of additional ground being legal is taken up for hearing first. The ld. AR submitted that the cross objections of the assessee being ITA Nos. 17 & 18/Del/2015 are delayed by 1297 and 1244 number of days but as per the notice issued by the ITAT Registry, there was delay of 1266 and 1211 days. Elaborating the reasons for delay, the ld. Counsel has drawn our attention towards the application for condonation of delay and affidavits of the Director of the assessee company and subm .....

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or condonation of delay in filing the cross objections. The ld. AR further submitted that on his instructions, the assessee immediately proceeded to file the cross objection alongwith other necessary applications and delay in filing the cross objection has been caused on account of no such advice or incorrect advice by the earlier counsel which is a reasonable and bonafide cause for delay in filing the cross objection. The ld. AR further submitted that the issue raised in cross objection is lega .....

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ate of service of Form No. 36A is also not known. Therefore, the bonafide delay in filing the cross objection may kindly be condoned and the cross objection of the assessee may kindly be accepted for adjudication. The ld. AR placed reliance on various decisions including the decision of ITAT Mumbai in the case of Perfect Scale Pvt. Ltd 60 SOT 255 [Mumbai Tribunal]. 4. The ld. DR strongly opposed the application for condonation of delay in both the appeals and submitted that the delay cannot be c .....

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d that the company received the order ITA Nos.3228 to 3234/2013 of CIT(A) dated 1-10-2011 and the appeal should have been filed before the Tribunal within 60 days. It is further explained that the appeal matters of the assessee were looking after by Mr. P.K.Tandon, Chartered Accountant and on his advice the appeals were not filed. However, when the assessee transferred the case to Mr. S.S. Gajja, Chartered Account, who advised that appeals are to be filed before the Tribunal as the order of the .....

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la Devi and others, reported in (1979) 118 ITR 507(SC), has been considered, wherein it has been held that the mistake of the counsel may in certain circumstances be taken into account in condoning the delay although there is no general proposition that mistake of counsel by itself is always a sufficient ground. Accordingly, the Hon'ble Apex Court has held that there is a mistake of the counsel and, therefore, the delay in filing the appeal has been condoned. I further noted that similar fin .....

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iew of the above facts and circumstances of the case and in view of the various decisions mentioned above, which was considered by the Tribunal in the case of The Phoenix Mills Ltd (supra), I condone the delay in filing the present appeals before the Tribunal for all the years. Also heard on merit of the case . 6. In view of the above, it was held by the Coordinate Bench of the Tribunal that where it was due to wrong advice of the Chartered Accountant that the appeal was not filed on time, then .....

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n this situation, we are inclined to hold that there was a bonafide reason and cause due to which cross objections could not be filed on time and delay was caused which cannot be attributed as wilful omission or negligence on the part of the assessee. Therefore, respectfully following the dicta of ITAT, Mumbai in the above mentioned case, the application for condonation of delay in filing the appeals are hereby allowed. Application of the assessee for admission of additional ground in both the c .....

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dly be admitted for adjudication. The ld. AR placed reliance on the proposition laid down by the Hon'ble Supreme Court in the case of National Thermal Power Company Ltd reported in 229 ITR 383 [Hon'ble Supreme Court] submitting that the issue which is purely legal and which goes to the root of the matter and no new facts are required to be invoked, then the same should be admitted for adjudication being legal objection of the assessee. The ld. AR also placed reliance on the decision of t .....

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ed the submissions of the assessee as well as of the Revenue on admission of additional ground raised by the assessee which was not raised before the first appellate authority and referring and following the dicta laiddown by the Hon'ble Apex Court, in the case of NTPC [supra] wherein it has been held as under: 6.1. Since the additional ground raised by the assessee firm, according to us, being a legal issue which goes to the root of the matter, we were of the view that it was paramount to t .....

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t whether a notice u/s 143(2) of the Act is issued or not was only a question of fact and not a question of law. It was also pointed out by the learned DR that the alleged non-issuance of a Notice u/s 143(2) of the Act was neither raised before the assessing officer or nor before the first appellate authority and, therefore, it was argued, a new case (issue) cannot now be raised before the Tribunal for the first time. In this connection, the learned DR had relied on the findings of the Tribunal .....

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ted 06.08.2014 the content of the same is reproduced below:- "Note on applicability of Delhi High Court judgment in Alpine Electronics Asia P Ltd. (341 ITR 247 Del) in CO No. 122/D/2013 in ITA 1809/D/2013 filed by Silverline for AY 2008-09 Before discussing as to how the facts of the Delhi High Court judgment in Alpine Electronics Asia Pvt. Ltd. ( 341 ITR 247 Del) are distinguishable it will be relevant to keep in mind the provisions of section 292BB of the Income Tax Act, 1961 which provid .....

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roceedings had not got completed (only a draft order was proposed) by the time when service of notice u/s 143(2)(ii) was challenged before the High Court by way of Writ Petition. Since, the challenge has been there before the completion of the assessment or reassessment proceedings the High Court in para 28 held that benefit of saving as provided u/s 292BB is not available to Revenue and hence Writ of Certiorari was issued quashing the assessment proceedings. 02. In so far as the facts of the CO .....

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nge at all the service of notice till the conclusion of the assessment proceedings by virtue of provisions of section 292BB the assessee is estopped from challenging the reassessment proceedings on account of non-service or improper service or non- service in time of notice u/s 143(2) of the Act. 04. From the above, it is clear that reliance placed by the Cc- Object on Delhi High Court judgment on Alpine Electronics Asia Pvt. Ltd. (341 ITR 247 Del) is misplaced and it on the contrary is in favou .....

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t obtained from the assessing authority [source: P 88 of PB-I]. According to the learned AR, the assessing authority had admitted also in response to a query under RTI Act that no notice u/s 143(2) of the Act was issued. Rebutting the learned DR's argument that the additional ground raised in Cross Objection cannot be acted upon in lieu of s. 253(4) of the Act, the learned AR had placed strong reliance on the judgment of the Hon'ble Gauhati High Court reported in 234 ITR 663 (Gau). The i .....

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n, the learned AR drew strength from the findings of the earlier Bench of this Tribunal in ITA No. 6020/Del/2012 dated 29.5.2014 in the case of B.R.Arora v. ACIT. 6.5 Further, it was submitted by the learned counsel that Section 292BB is applicable only from A.Y. 2008-09 onward in light of dictum laid down by the Hon'ble Special Bench of the Tribunal in case of Kuber Tabacco Products (Pvt.) Ltd. reported in 117 ITD 273 (Delhi) (S.B), which was affirmed by the Hon'ble Delhi H.C. by judgme .....

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r this proposition, the learned AR had placed strong reliance on the following case laws, namely: (i) B.R.Arora v. ACIT in ITA No.6020/D/2012 dated 29.5.2014 - ITAT, Delhi 'A' Bench; (ii) Alpine Electronics Asia Pte Ltd v. DGIT & Ors. (2012) 341 ITR 247 (Del); (iii) ITO v. D.D. Ahuja & Brothers - 158 TTJ (Lucknow) 54; (iv) Sapthagiri Finance and Investments v. ITO (2013) 90 DTR 289 (Mad); (v) Rajkumar Chawla 94 ITD 1 (Del) (SB); (vi) CIT v. K.M.Ravji (Tax Appl No.771/2012, Order .....

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P Ltd. Delhi HC 06.10.2010: 2.1 Before dealing with the applicability of the aforesaid judgments which hover around the provisions of section 143(2), 292BB in the context of issuance of the notice and service thereof etc. It is pointed out that all these provisions as contained in the Income Tax Act or the Income Tax Rules talk about the 'service of the notice' alone obviously become upon service issuance is implicit. That is why, the law also as contained u/s 143(2) etc. does not provid .....

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e service of the notice and not beyond. Reading the word issuance' u/s 292BBwhich law does not talk so would only tantamount to keeping oneself busy in writing the law which is the exclusive domain of the legislature and not of the Courts. 2.3 What fun would it make when the notice so issued is not even served. Kindly appreciate without service the assessee cannot be legally expected to appear in the proceedings for which service of the relevant notice is a must. How an assessee can particip .....

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is to be served we have to form understanding with the help of other sources like Dictionaries which define the 'Notice' to mean information, knowledge of the existence of a fact or to apprise a person of some proceeding in which his interest are involved. Black's Law Dictionary (5th Edition) provides 'a person has notice of a fact if he knows the fact' and that it can be in many ways like implied, constructive etc. When seen in the context of the present case undisputed serv .....

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just at the time of its accrual, arisal or receipt (and not mere quantum). Since, these are merely procedural provisions, they will apply to procedures which are initiated on or after the particular date from which it is brought on the statute which in this case was 01.04.2008. 2.6 As mentioned in this particular case the procedure of reassessment started with the service of notice u/s 148 (served on 28.03.2011) by which time amendment on the statute has already become effective. Accordingly, th .....

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hort, it is pointed out that law as contained u/s 143(2) etc. does not provide that notice intended to be issued has to be necessarily in writing or in a particular proforma. Participation in the proceedings is undisputedly the best evidence to prove issuance or service of the notice that is why section 292BB taking note of this crucial aspect post participation has disabled the participants from challenging the frivolous grounds of non service of the notice. Service of the written notice issued .....

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p; 1506 /Del/ 2013 C.O. Nos.122, 109, 107 & 108 /Del/2013 appreciated that Finance Act is always for the financial year for which budget is being laid before the Parliament. It is why, Finance Act is generally in the context of the income which has been earned on which likely revenue realization can be worked out as such except where it is specifically provided as to form which particular date that will apply. But this has no relation with the procedural provisions which would apply with eff .....

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s yet for the sake of further clarity qua the inapplicability these are being dealt with in the following paragraph 5.1 to 5.3. 5.1 In so far as Delhi High Court judgment in Kuber Tobacco Products P Ltd. Delhi HC 06.10.2010 is concerned it is humbly submitted that this does not help the cause of the appellant assessee. Before elaborating this aspect further, it will be relevant to note as to what the High Court has held which is as under: "In our view ITAT rightly held that 292BB is not ret .....

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s so clearly the observations of the High Court "We hold that section 292BB is applicable to AY 08-09 and later years" are just obiter dictum. Even without these words the judgment of the High Court would have remained the same which further proves that above were just 'by the way remarks' and not the ratio which is a must for applying any High Court judgment. In this context, attention is invited to the Supreme Court judgment in Rekha Mukherjee v. Ashok Kumar Das {(2005) 3 SCC .....

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Likewise the Punjab and High Court judgment in Parikalpana E-state 79 DTR 246) also proceeds on the assumption that law mandates issuance of the notice whereas (as demonstrated above) law does not lay emphasis on ITA Nos.1809, 1504, 1505 & 1506 /Del/ 2013 C.O. Nos.122, 109, 107 & 108 /Del/2013 issuance and instead lays stress on 'service' of the notice. Thus, this too is not applicable. 5. Submitted for kind consideration." 7. We have carefully considered the rival submissio .....

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are inclined to admit the same and taken up for consideration. 7.1. Now, the moot question for consideration is: Whether the non-issuance of a notice u/s 143(2) of the Act as alleged by the assessee-firm had vitiated the conclusion of the assessments u/s 147 read with s. 143(3) of the Act? On receipt of information from the DIT (Inv), Jaipur that there were alleged bogus purchases resorted to by the assessee firm, the AO had reopened the assessments of the assessee for the assessment years under .....

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erusal of the Order Sheet for the AY 2005-06 [Source: P 88 of PB-I AR]. This fact has been admitted by the Revenue through a RTI query by the assessee firm [Refer: P 165 of PB AR (A.Y.2006-07)]. The above sequence of events categorically proves that notice u/s 143(2) of the Act was neither issued nor served on the assessee. 10. In view of the above, respectfully following the proposition, we hold that since the additional ground sought to be raised is legal in nature and goes to the root of the .....

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, the penalty order, impugned order, paper book filed by the assessee, and paper book of compilation of cases filed by the assessee as well as the written submissions of the assessee, reply of the ld. DR and rejoinder of the assessee. 12. The ld. AR vehemently pointed out that the first notice u/ss 271D and 271E dated 31.12.2009 was issued by the AO who framed the original assessment orders and second notice dated 26.7.2010 fixing the hearing on 9.8.2010 was issued by the Additional CIT who pass .....

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limitation of six months should be calculated with regard to the first notice issued by the AO and penalty order was to be passed on or before 30.6.2010 which were actually passed on 4.1.2011. Therefore, under the facts and circumstances of the case, the impugned penalty orders levying penalty u/s 271D & 271E of the Act is barred by limitation and the same may kindly be quashed, allowing the objection of the assessee. 13. Per contra, the ld. DR supported the orders of the AO and submitted t .....

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sions of section 269SS of the Act. The ld. DR further submitted that the assessee company had not carried out any business during the period under consideration and there was no business exigencies to receive loan or deposit in cash from the Director. The ld. DR was of the view that the cases relied upon by the ld. CIT(A) had no similarities with the facts of the assessee s case. He further vehemently argued that the ld. CIT(A) deleted the penalty without giving an opportunity of being heard to .....

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on the decision of the ITAT Delhi Bench in the case of Ashwani Kumar Vs. ITO reported at 118 TTJ 483 [Del], the decision of the Hon'ble Jurisdictional High Court in the case of Jitendra Singh Rathore 352 ITR 327 [Raj] and decision of the Hon ble Bombay High Court in the case of CIT Vs. Chajjer Packaging & Plastics Pvt. Ltd. 206 Taxmann 690 [Bombay] and submitted that in the penalty proceedings, the time limit prescribed u/s 275(1)(c) of the Act has to be completed either with the F.Y. of .....

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careful consideration of above rival submissions, at the very outset, we note that in the case of CIT Vs Jitender Singh Rathore [supra] the Hon'ble Rajasthan High Court in similar set of facts and circumstances, held as under: In the present case, the notice for issuance of the penalty proceedings under Section 271D of the Act for the alleged contravention of provisions of Section 269SS was issued to the assessee, of course by the AO, on 25.03.2003. Even if the matter had otherwise been in a .....

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c) could be noticed as under:- "275. Bar of limitation for imposing penalties. (1) No order imposing a penalty under this Chapter shall be passed- ....... (c) in any other case, after the expiry of the financial year in which the proceedings, in the course of which action for the imposition of penalty has been initiated, are completed, or six months from the end of the month in which action for imposition of penalty is initiated, whichever period expires later." In the present case, th .....

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ugned. In view of the above, our answer to the formulated question of law is that even when the authority competent to impose penalty under Section 271D was the Joint Commissioner, the period of limitation for the purpose of such penalty D.B. INCOME TAX APPEAL NO.90/2007 Commissioner of Income Tax, Udaipur Vs. Shri Jitendra Singh Rathore. proceedings was not to be reckoned form the issue of first show cause by the Joint Commissioner; but the period of limitation was to be reckoned from the date .....

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ontroversy with the following observations and conclusion: 11. As regards limitation, we find that the limitation as prescribed in s. 275(1)(c) alone is made applicable. Sec. 275(1)(c) prescribes as under : "275(1) No order imposing a penalty under this chapter shall be passed- (a)............... (b).................. (c) in any other case, after the expiry of the financial year in which the proceedings, in the course of which action for the imposition of penalty has been initiated, are com .....

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h Jan., 2003, the ITO has clearly recorded a finding that since the assessee has violated the provisions of s. 269SS of the Act for which a separate show-cause notice has been issued vide notice dt. 10th Jan, 2003, penalty proceedings are being initiated for committing the default for accepting loan in cash i.e. through bearer cheque . This conclusively proves that the action for imposition of penalty has been initiated on 10th Jan., 2003 as recorded in assessment order dt. 27th Jan, 2003. It is .....

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ing his powers. But, merely because he chooses to exercise his powers after a considerable time he cannot get a fresh limitation if on earlier occasion, the action for imposition of penalty has already been initiated. He can only continue the action earlier taken and in all cases the order imposing penalty shall be passed within the limitation prescribed under s. 275(1)(c). Since the action for imposition of penalty has been initiated on 10th Jan., 2003, as per s. 275(1)(c), the limitation perio .....

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"Assessment of taxable income of respondent for the asst. yr. 1996-97 (financial year 1995-96) was carried out by the Departmental authorities and concluded with assessment order dt. 30th March, 1999. The AO [Dy. CIT (Inv.), Circle II, Jalgaon], during the course of assessment noticed that the assessee had accepted loans/deposits exceeding ₹ 20,000 by modes otherwise than account payee cheques/demand drafts and had thus contravened s. 269SS of the Act. By his letter dt. 30 March, 199 .....

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responding assessment year being 19992000. Consequently, penalty could have been imposed latest by 31st March, 1999 since the assessment proceedings out of which penalty proceedings took birth, were completed on 30th March, 1999. So far as second mode of computation of limitation is concerned, the later half of the cl. (c) of s. 275(1) of the Act is not that difficult to be understood. The penalty proceedings in the present matter were initiated by notice dt. 6th April, 1999 and the period of li .....

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999. 29th Oct., 1999 being later in time, that was the available outer limit for the Department to impose penalty. The order imposing penalty is passed on 13th March, 2000. Coming to the opening part of sub-s.(1), it says, no order imposing penalty............. shall be passed . Thus, once the period of limitation prescribed by either of cls. (a) to (c) has expired, the Departmental authorities have no powers to impose penalty. The opening part rules out any possibility of taking initiation of p .....

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oposition laid down by the Hon'ble Rajasthan High Court and ITAT, Delhi [supra], when we analyze the facts and circumstances of the case in hand, then undisputedly and admittedly the first notice for initiation of penalty proceedings u/s 271D and 271E of the Act was issued by the AO on 31.12.2009 who framed the original assessment orders and the other notice dated 26.07.2010 was issued by the Additional CIT who passed the penalty order on 4.1.2011. The ld. AR has contended that the period of .....

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d that the penalty orders cannot be held as barred by limitation. To support this contention, the ld. DR ha placed his reliance on the decision of ht Hon'ble Jurisdictional High Court in the case of Sunworld Infrastructure P. Ltd Vs. ITO dated 5.3.2015 in WP(C) No. 1741/2015 and CM No. 3112/15. 18. In the case of Sunworld Infrastructure Pvt. Ltd. Vs. ITO [order dated 5.3.2015 in WP No. 1741/2015 and CM No. 3112/2015] as relied upon by the ld. DR, the Hon'ble Jurisdictional High Court of .....

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s of the case to Delhi. Their Lordships also observed that if the case itself had been transferred, the same would have to be directed u/s 127 of the Act but no such order of transfer of the case has been made. In the light of the above noted circumstances, their Lordships held that the notice issued by the AO of Bangalore cannot be regarded as a valid notice and the notice issued by the AO of Delhi having jurisdiction over the assessee was, on 24.12.2014 was held as time barred i.e. beyond 30.9 .....

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scribed in the second proviso to section 143(2) cannot be equated with sub-section (c) of section 275(1) of the Act as provisions of section 143(2) mandates limitation for service of notice whereas sub-section (c) to section 275(1) of the Act prescribes limitation for passing of penalty order reckoning from the date of issuance of notice. 20. In view of the above, we decline to accept the contentions of the ld. DR that the limitation for initiation of penalty proceedings has to be calculated fro .....

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