CA Aman Rajput
Quick Summary
While reading some concepts of the Limitation Act in my LLB syllabus a thought came to my mind that can we Combine the Limitation Act and the Income Tax Act? In the intricate world of tax litigation, taxpayers often find themselves entangled in a web of complex legal procedures and time-bound lim
Daily Limit Reached
You have reached your daily limit of 2 Free Articles
Subscribe to CCI PRO for unlimited access
Why Upgrade to CCI PRO?
- No Ads
- WhatsApp Broadcasts
- Daily E-Newsletter
- Unlimited Articles Access
BEST VALUE
2 YEAR PLAN
3,499
(Inclusive of GST)
1 YEAR PLAN
1,999
(Inclusive of GST)
View all CCI PRO benfits
Already a PRO member? Login here for an ad-free experience.
FAQ :
Section 14 of the Limitation Act is designed to protect bona fide litigants by allowing the exclusion of time spent pursuing legal remedies in good faith from the overall limitation period.
The Delhi High Court ruled that the principles of Section 14 of the Limitation Act can be applied to proceedings under the Income Tax Act, even though the Income Tax Appellate Tribunal (ITAT) is not strictly a 'Court'.
This ruling potentially allows taxpayers to benefit from the time exclusion provisions of Section 14 when dealing with tax disputes before bodies like the ITAT, preventing them from being unfairly penalised by procedural delays.
The applicability of Section 14 to rectification proceedings is still a subject of debate. While some argue for its extension based on fairness, others believe its informal nature may warrant a more cautious approach.
The decision signals a trend towards a more nuanced approach in tax litigation, where fairness and the pursuit of justice are prioritised over strict adherence to technicalities, blurring the lines between the Limitation Act and the Income Tax Act.
CAclubindia
