Limitation for penalty proceedings begins at the range head, requiring assessing officers to refer and not issue penalty notices. Limitation for imposition of penalties under sections 271D and 271E commences at the Range Head (Joint/Additional Commissioner), not at the Assessing Officer; Assessing Officers should refer alleged violations of section 269SS/269T to the Range Head who will issue penalty notice and complete proceedings within the prescribed limitation period, and conflicting High Court decisions will render the Departmental View inoperative in that High Court's area while the matter is referred to the Central Technical Committee for consideration.
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Provisions expressly mentioned in the judgment/order text.
Limitation for penalty proceedings begins at the range head, requiring assessing officers to refer and not issue penalty notices.
Limitation for imposition of penalties under sections 271D and 271E commences at the Range Head (Joint/Additional Commissioner), not at the Assessing Officer; Assessing Officers should refer alleged violations of section 269SS/269T to the Range Head who will issue penalty notice and complete proceedings within the prescribed limitation period, and conflicting High Court decisions will render the Departmental View inoperative in that High Court's area while the matter is referred to the Central Technical Committee for consideration.
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