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Conceding the contention of Vijay that the punitive action was time-barred, the judge granted the interim injunction.
In his petition, Vijay sought to quash the order of the I-T department pertaining to the assessment year 2016-17. He said that the notice dated December 11, 2018 demanding the fine amount for 2016-17 was time-barred and hence it is invalid.
The IT department had failed to appreciate the fact that having completed the assessment on December 30, 2017, the penalty proceedings u/s 271AAB of the IT Act for the surrendered income/ undisputed income should be initiated and completed on or before June 30, 2018.
Any show-cause notice issued beyond that date should be considered as nullity in law, he claimed.
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