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    <title>2015 (9) TMI 111 - ITAT DELHI</title>
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    <description>Penalty proceedings for violation of section 269SS were treated as independent of the assessment proceedings, so limitation for penalty under section 271D was governed by section 275(1)(c). On the stated facts, the penalty order was passed beyond six months from the end of the month in which assessment was completed, and also beyond six months from the notice dated 7.3.2011 referred to in the order. The penalty was therefore time-barred and the order was rightly set aside.</description>
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      <description>Penalty proceedings for violation of section 269SS were treated as independent of the assessment proceedings, so limitation for penalty under section 271D was governed by section 275(1)(c). On the stated facts, the penalty order was passed beyond six months from the end of the month in which assessment was completed, and also beyond six months from the notice dated 7.3.2011 referred to in the order. The penalty was therefore time-barred and the order was rightly set aside.</description>
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