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of The HC held that the penalty under section 271E is time-barred: the limitation prescribed by section 275(1)(c) expired on 30.06.2011, and the Revenue cannot unilaterally extend limitation by delaying issuance of notice. Because the departmental reference was made on 07.06.2011, any consequential notice and the penalty order dated 30.12.2011 were issued after expiry of the statutory limitation. Accordingly, the penalty order is invalidated and the appeal succeeds in favor of the respondent/assessee, with relief granted against the Revenue.
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