DCIT, CENTRAL CIRCLE-2, JAIPUR, JAIPUR vs. KAMLAPRABHA L/H OF LATE SHRI GOPAL LAL JI GOSWAMI, KOTA

In the result, the appeal of the revenue is dismissed and the Cross objection of the assessee is disposed off in terms of the observation made herein above

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

penalty imposable under Chapter XXI is to be initiated and completed within two years.  Action of the CIT u/s 263 of the Act is to be taken within two years from the end of the financial year in which the order sought to be revised was passed. 1.3Even where no limit is prescribed for taking an action under