24 results for “penalty u/s 271”+ Section 153(2)clear
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Appeals are allowed
Bench: Shri Vijay Pal Rao & Shri B.M. Biyani
271(1)(c) is reckoned from the date of the assessment order dated 6.11.2007, the penalty order passed by the Joint Commissioner on 29.7.2008 is beyond the time permitted in the above section. As we have already held, the initiation of the penalty proceedings is not by the Assessing Officer but by the Joint Commissioner and if that