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of <h1>Clarification on Limitation Period for Penalty Proceedings u/ss 271D & 271E of Income Tax Act Announced.</h1> The circular addresses conflicting interpretations by various High Courts regarding the commencement of limitation for penalty proceedings under sections 271D and 271E of the Income Tax Act, 1961. It clarifies that the limitation period begins with the issuance of a notice by the Joint Commissioner of Income Tax, not with the assessment order by the Assessing Officer. This aligns with a judgment by the Kerala High Court. Assessing Officers are advised to refer potential violations to the Range Head, who will issue penalty notices. If a High Court ruling contradicts this view, the matter should be reported for potential appeal or legislative amendment.
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