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Section 158BFA of the Income Tax Act, 1961— Block assessment — Pursuant to Supreme Court's order deciding quantum appeal in revenue's favour, dormant penalty proceedings were also reinstated, plea raised by assessee that since penalty proceedings had been initiated after expiry of prescribed period of six months from Tribunal's order, same were barred by limitation under section 158BFA(3)(c), deserved to be rejected — S. Ajit Kumar vs. Assistant Commissioner of income tax [2019] 266 Taxman 380 (Madras)