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Penalty under section 271D was time-barred because section 275(1)(c) required the penalty order to be passed within six months from the end of the month in which the penalty notice was issued. The notice was issued in January 2021, making July 2021 the statutory deadline; the March 2022 order fell outside that period. The penalty order was therefore invalid and quashed, and the appellate order was set aside.
Penalty under section 271D was time-barred because section 275(1)(c) required the penalty order to be passed within six months from the end of the month in which the penalty notice was issued. The notice was issued in January 2021, making July 2021 the statutory deadline; the March 2022 order fell outside that period. The penalty order was therefore invalid and quashed, and the appellate order was set aside.
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