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Section 275(1)(c) Limitation Runs From AO’s Initiation, Not JCIT/Addl. CIT Notice
Case Law Details
- Case Name
- PCIT Vs Thapar Homes Pvt. Ltd. (Delhi High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2009-10
- Courts
- All High Courts, Delhi High Court
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PCIT Vs Thapar Homes Pvt. Ltd. (Delhi High Court)
Limitation period under Section 275(1)(c) starts from the AO’s initiation of proceedings in the assessment order, not from the JCIT/Addl. CIT notice.
Assessee, Thapar Homes Pvt. Ltd., was subjected to scrutiny for AY 2009-10. AO completed assessment u/s 143(3) on 31.12.2010, recording that penalty proceedings u/s 271E would be initiated separately for violation of Sec 269T. Subsequently, AO made a reference to the Addl CIT on 07.06.2011 & Addl CIT passed penalty order on 30.12.2011, imposing penalty of ₹3.44 crore, e...
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