Tube Investments Of India Ltd., Chennai vs Assessee
7. The ld. DR, while relying upon the basis and reasonings as given by the ld.
CIT(A) has pleaded that since the Hon'ble Madras High Court's decision is there in
favour of the Department in the case of M/s. Rayala Corporation Limited Vs. Union
8 I.T.A. Nos
Nos.1757 & 1920/Mds/10
of India & Other (supra) and in this case there was a further appeal the ITAT and
order of penalty has been passed within six months from the end of the month in
which the Tribunal order has been received, therefore, penalty order passed is well
within the prescribed time and the ld. CIT(A) has rightly concluded to reject the
plea of the assessee.