The case deals with the limitation period for initiating penalty...

The case deals with the limitation period for initiating penalty proceedings u/s 271E of the Income Tax Act. It is well-established that the limitation period commences from the date of issuance of notice by the Assessing Officer, not from the subsequent notice by the Joint/Additional Commissioner. In this case, the Assessing Officer issued the penalty notice on 31/12/2010 along with the assessment order, while the Additional Commissioner issued another notice on 30/06/2011. The initial notice by the Assessing Officer remains valid and operative. Therefore, the imposition of penalty u/s 271E should have been done before 30/06/2011, not 31/12/2011. The CIT(Appeals), following judicial precedents and CBDT Circular, rightly deleted the penalty, and the Tribunal dismissed the Revenue's appeal, finding no merit.