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3 orders · Page 1 of 1
The Tribunal held that notices issued under Section 148 were beyond the period of limitation, as amendments to Section 149 were not retrospective and could not revive expired time limits. Therefore, the reassessment proceedings and subsequent orders were quashed.
The Tribunal held that the AO had made necessary inquiries and the assessee had provided sufficient details, including ledger copies, bank statements, and ITR acknowledgments. The PCIT failed to specify what further inquiries should have been made by the AO, and therefore, the revisionary order was not sustainable.
The Tribunal held that while a penalty is leviable for non-compliance, it should be restricted to the first default. The penalty for subsequent defaults for the same issue is not intended by the legislature.