When can Category B Offences not be compounded?
First Offence' means:

(a)  Offences which are committed prior to earlier of the following:

Date of issue of any letter or notice in relation to the prosecution;
Intimation relating to filing of prosecution complaint sent by the department to the persons concerned; or
Launching of the prosecution;
(b)  Offences which were not detected by the department but voluntarily disclosed by the assessee with the filing of application of compounding of offence for one or more assessment years.

To determine the first offence, the offence is relevant if it is committed by the same person or the same entity. The first offence is to be determined separately for each of the Category B offences.​