Penalty proceedings reinitiated pursuant to SC's order weren't barred by limitation due to doctrine of merger: HC

INCOME TAX: Where pursuant to Supreme Court's order deciding quantum appeal in revenue's favour, dormant penalty proceedings were also reinitiated, 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

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