CMA Final · Direct Tax Laws and International Taxation · Penalties and Prosecutions
Penalty proceedings were initiated in the course of an assessment completed by order dated 12 August 2026 (quarter ending 30 September 2026). The assessment order was not appealed. Under section 472(1), the last date for passing the penalty order is:
The penalty order must be passed by 31 March 2027. Section 472(1)(a) allows six months from the end of the quarter in which the unappealed proceedings were completed; that quarter ended 30 September 2026.
- A31 January 2027
- B31 March 2027Correct
- C12 February 2027
- D30 September 2027
Explanation
Under section 472(1)(a) the period is six months from the end of the quarter in which proceedings are completed. The quarter ends 30 September 2026, and six months from then is 31 March 2027. 12 February 2027 wrongly counts from the order date.
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