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of HC dismissed petition challenging penalty proceedings under s271DA. AO initiated proceedings via reference to Addl. CIT within 11 days of assessment order completion (08.04.2024), following assessment order dated 28.03.2024. Six-month limitation period commenced from reference date. Court held timing reasonable, rejecting petitioner's argument of arbitrary extension. While acknowledging that inordinate delays require scrutiny and reasonable timeframe applies where no specific limitation exists, HC found 11-day gap between assessment completion and penalty initiation well within acceptable bounds. Proceedings deemed within limitation period prescribed under s275(1)(c).
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