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of ITAT held that penalty order u/s 271C was barred by limitation. As per s. 275(1)(c), limitation began from date when AO recommended initiation of penalty proceedings to ACIT. Last date for passing penalty order was 30.06.2014, but it was passed on 14.07.2016, making it time-barred. Assessment order incorrectly initiated penalty for non-compliance of s. 192(1), while penalty order referred to ss. 194C/194J based on erroneous facts, showing non-application of mind. Revenue's appeal dismissed.
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