2025 (1) TMI 97

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..... consequential order herein was passed on 26th July, 2023. That being the case, it admittedly does not satisfy the clinching statutory condition of six months from the end of the month in which action for imposition of penalty is initiated . Although the department has indeed sought to get out of the rigor of the impugned limitation period, the factual position which goes unrebutted is that the im .....

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..... d lower authorities impugned action levying section 271DA penalty in his hands is barred by limitation under section 275(1)(c) of the Act. There is no dispute of the clinching factual position that the same had been initiated in the assessment order dated 21.12.2020 itself and consequential order herein was passed on 26th July, 2023. That being the case, it admittedly does not satisfy the clinchin .....

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