SUNDEEP KAPILA,HIMACHAL PRADESH vs. ADDITIONAL COMMISSIONER CENTRAL, CHANDIGARH
In the result, all the appeals filed by the assessee are allowed
ITA 1068/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh06 Aug 2025AY 2017-18
Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)
For Appellant: Sh. Saurav Rohatgi, CA and Shri Rajat Mittal, CAFor Respondent: Smt. Priyanka Dhar, Sr. DR
Section 133ASection 147Section 269SSection 271DSection 275(1)(c)
section 275(1)(c), the relevant date is the date of reference by the Assessing Officer, i.e., 26.06.2023, and therefore the last permissible date for passing the penalty order was 31.12.2023. Since the order was passed on 28.02.2024, it is clearly beyond the prescribed limitation.
17. On the other hand, the Revenue argued that the limitation should be reckoned from