Penalty U/s. 271E not valid in absence of finding in order of AO with regard to applicability of section 269T

CIT Vs Manohar Lal Thakral (Punjab and Haryana High Court)

The Tribunal while deleting the penalty recorded that the return of the assessee was processed as on 31.12.2003 and the notice u/s 274 read with section 271E of the Act was issued on 12.06.2007. Such notice was issued when there was no proceedings pending before the Assessing Officer. Relying upon Delhi High Court judgment in Commissione

Please become a Premium member. If you are already a Premium member, login here to access the full content.