L. T. Stock Brokers Pvt. Ltd. v. CCIT (Bom) (HC)(UR)

S. 279 : Offences and prosecutions-Sanction-Chief Commissioner-Commissioner-Compounding of offence-Compounding application could not have been rejected on delay alone-Limitation-CBDT guidelines dated 16 November 2022.[S. 279(2), Art.226]

CBDT guidelines dated 23 December 2014. In the context of such guidelines and clauses like Clause 9 of the 2022 guidelines, this Court held that since the Income-tax Act had provided for no period of limitation to apply for compounding, such period could not have been introduced through guidelines. In any event, no rigid timeline could have been introduced through such guidelines. This Court held that the compounding application could not have been rejected on delay alone. Order is set aside. [W.P.(L) 21032/2024, Dated: 04/03/2025

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