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The ITAT held that penalty orders under sections 271(1)(c) and 270A for the assessment years 2014-15 to 2018-19 were barred by limitation under section 275(1)(c) of the Act. Since the penalties were imposed beyond six months from the end of the month in which penalty proceedings were initiated, such orders are illegal, void ab initio, and bad in law. Consequently, the penalties for concealment and underreporting of income were quashed. The assessee's appeal was allowed on the ground of limitation, consistent with the precedent that penalty orders passed after the prescribed limitation period are invalid.
The ITAT held that penalty orders under sections 271(1)(c) and 270A for the assessment years 2014-15 to 2018-19 were barred by limitation under section 275(1)(c) of the Act. Since the penalties were imposed beyond six months from the end of the month in which penalty proceedings were initiated, such orders are illegal, void ab initio, and bad in law. Consequently, the penalties for concealment and underreporting of income were quashed. The assessee's appeal was allowed on the ground of limitation, consistent with the precedent that penalty orders passed after the prescribed limitation period are invalid.
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