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ITAT held that the penalty under section 271E for alleged contravention of s.269T is time-barred and therefore quashed. The Tribunal found that an order under s.143(3) was passed on 02/05/2017, making the relevant assessment year end 31/03/2018 and the six-month period from the month of initiation expire on 30/11/2017, fixing the limitation to 31/03/2018. Even if the s.263 order dated 08/03/2021 is taken for limitation reckoning, the six-month period expired on 30/09/2021 and the limitation would be 31/03/2021. The impugned penalty dated 31/08/2022 exceeded the period prescribed by s.275(1) and was quashed; appeal of the assessee allowed.
ITAT held that the penalty under section 271E for alleged contravention of s.269T is time-barred and therefore quashed. The Tribunal found that an order under s.143(3) was passed on 02/05/2017, making the relevant assessment year end 31/03/2018 and the six-month period from the month of initiation expire on 30/11/2017, fixing the limitation to 31/03/2018. Even if the s.263 order dated 08/03/2021 is taken for limitation reckoning, the six-month period expired on 30/09/2021 and the limitation would be 31/03/2021. The impugned penalty dated 31/08/2022 exceeded the period prescribed by s.275(1) and was quashed; appeal of the assessee allowed.
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