Limitation for penalty imposition: time limits bar penalty orders, with extended period where an appeal is pending. Substituted section 275 prescribes limitation periods for imposing penalties: where the assessment or order is under appeal, penalty orders are barred after the later of two years from the end of the financial year in which the proceedings initiating penalty action are completed, or six months from the end of the month in which the appellate order is received; in other cases, penalty orders are barred after two years from the end of the relevant financial year. Time taken for re hearing and periods of judicial stay are excluded from the limitation computation.