Section 472 - Bar of limitation for imposing penalties.

Penalty orders must be issued within six months of quarter-end after relevant appeal, revision, or notice; hearing required

Penalty orders under this Chapter must be issued within six months from the end of the quarter in which: the underlying proceedings are completed (if no appeal under sections 356, 357 or 362), a revision order is passed, the appellate order is received by the jurisdictional Principal Commissioner/Commissioner, or a penalty notice is issued in other cases. Penalty orders may be revised to give effect to assessment appellate or revision outcomes, but no order under that power may be passed without hearing the assessee and after six months from the quarter-end when the relevant appellate or revision order is received or passed. Section 471(2) applies, and time for rehearing under section 244(2) and periods of court-ordered stays are excluded in computing limitation.