Section 274(2) of the Income Tax Act
Income-tax Act, 2025: s.471
Section 274(2) falls under section 274 of the Income-tax Act, 1961, which corresponds to section 471 (Procedure) of the Income-tax Act, 2025.
Read section 471 of the 2025 Act
Correspondence checked against the ICAI tabular mapping of the two Acts and the BharatTax.co section commentary.
The decision most relied on for Section 274(2) is Commissioner of Income Tax (TDS) v. IKEA Trading Hong Kong Ltd. (333 ITR 565), cited in 34 of the 42 judgments on BharatTax that turn on this section.
Leading authorities on Section 274(2)
The date of issuance of a Show Cause Notice (SCN) for penalty is the relevant starting point for calculating the limitation period for passing penalty orders.
Appeals related to statutory limitation periods for penalty proceedings are decided by considering relevant High Court judgments.
