AJAY BAKLIWAL,KOTA vs. ACIT, CENTRAL CIRCLE, KOTA, KOTA
In the result, the appeal of the assessee is allowed
ITA 1278/JPR/2024[2016-17]Status: DisposedITAT Jaipur11 Apr 2025AY 2016-17
Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)
For Appellant: Sh. Rajendra Sisodia, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 132Section 132(1)Section 269SSection 271DSection 274Section 275(1)(c)
269T, 271D,
271E, 275 (1) (c) ] Dismissing the appeal of the revenue, the Court held that; under section 275 (1) (c) of the Income-tax Act, 1961, the starting point of “initiation” of penalty proceedings, would be the date on which the Assessing
Officer wrote a letter to the Additional Commissioner recommending the issuance of the notice. Though the Additional