M/s Punjab National Bank v. The Jt. CIT(OSD)

Parties Involved

Facts Summary

The assessee, M/s Punjab National Bank, filed two appeals against the order of the Ld. CIT(A)/NFAC, Delhi dated 14/03/2023 pertaining to Assessment Year 2011-12. The order confirmed the decision of the AO under section 201(1) r.w.s 201(1A) dated 31/03/2018, which determined the tax and interest amounting to Rs. 16,79,223/-. Separately, the JCIT passed a penalty order under section 271C dated 02/07/2018. The assessee argued that the AO's order was barred by limitation and was passed ex-parte. The Tribunal set aside both orders and allowed the appeals for statistical purposes.…

Legal Issues

• 1. Whether the order passed by the AO under section 201(1) r.w.s 201(1A) is barred by limitation?
• 2. Whether the assessee was provided proper opportunity before the Ld. CIT(A)?

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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