Judgment Search Results Home > Cases Phrase: finance act 1968 section 28 amendment of section 280zb Court: income tax appellate tribunal itat cuttack Year: 1996

Sibonarayan Patro and Bros. Vs. Income Tax Officer.

Court : Income Tax Appellate Tribunal ITAT Cuttack

Reported in : (1996)54TTJCtk644

..... liable to be quashed. the learned counsel has also submitted before us that s. 44ab was introduced by the finance act, 1984, and while presenting the union budget for 1984-85, the then finance minister observed as under [(1984) 39 ctr (tlt) 34 at page 35 : (1984) 146 itr (st) 65 at page 66] : "with the reduction ..... subsequent incumbent ao has initiated the penalty proceedings. to our mind, taking the limitation period prescribed in s. 275 for initiation of penalty proceedings under the other sections of this chapter and also by respectfully following the judgment of the jurisdictional high court in the case reported in 1990 crlj 1110, maximum of two years from ..... of s. 275, which comes into operation from 1st april, 1989, initiation of penalty proceedings cannot be deferred unendingly and by taking the spirit of the section as a whole, the initiation of the penalty proceedings should take place within a reasonable period of time. the learned counsel for the assessee placed before us .....