Limitation for penalty orders under sections 271D and 271E barred the impugned orders as time expired under section 275(1)(c).

The Tribunal applied the limitation rule in section 275(1)(c) to penalties under sections 271D and 271E and held that the penalty orders had to be passed within the later of the two prescribed periods. On the facts, the impugned orders were passed beyond the permissible time limit, so the penalties were barred by limitation. The assessee therefore succeeded on the limitation issue.

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Issues: Whether the penalties levied under sections 271D and 271E were barred by limitation under section 275(1)(c).

Analysis: The Tribunal held that the limitation under section 275(1)(c) applied and that, on the facts, the penalty orders were required to be passed within the later of the two prescribed periods. It followed the binding interpretation of the limitation provision and found that the impugned penalty orders had been passed beyond the permissible period.

Conclusion: The penalty orders under sections 271D and 271E were held to be barred by limitation and the assessee succeeded on the limitation issue.

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