Summary
- The ITAT Mumbai has quashed a penalty order against Hardik Dayanand Patil, ruling it was passed beyond the limitation period under Section 275 of the Income Tax Act.
- The penalty, initiated after reassessment proceedings, was deemed void as it was issued on 23.11.2021, well past the extended deadline of 30.09.2021.
- The Tribunal rejected the Revenue's reliance on Supreme Court orders regarding pandemic-related extensions, emphasizing the specific statutory framework governing penalties.
- This decision underscores the importance of adhering to statutory limitations in tax proceedings, potentially impacting future penalty assessments.
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