MANISH SHARMA,KOTA vs. JCIT, CENTRAL CIRCLE, UDAIPUR
In the result, appeal of the assessee is allowed
ITA 619/JODH/2024[2011-12]Status: DisposedITAT Jodhpur25 Jun 2025AY 2011-12
Bench: Date Of Hearing.
Section 132(1)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 250Section 269TSection 271DSection 271E
271(1)(c) was concerned and not date on which SCN was issued – Held, yes – Whether, since Assessing Officer initiated penalty proceedings in December, 2008 and six months from end of month in which action of imposition of penalty was initiated expired on 30.06.2009, penalty order passed on 29.09.2009 was barred by limitation –
Held, yes [para 12][in favour