https://www.taxtmi.com/caselaws?id=178932 A jurisdictional plea challenging the limitation of a penalty order under section 271(1)(c) can be entertained under Rule 27 of the Income-tax (Appellate Tribunal) Rules even if the cross-objection is delayed, where the issue goes to the root of the matter. The proviso to section 275(1)(a) applies when the relevant first appellate order is passed on or after 1 June 2003, so penalty must be imposed within the statutory period computed from receipt of that appellate order. On the facts stated, the last permissible date was 31 March 2007, but the penalty order was passed on 20 April 2007 and was therefore time-barred. en-us Tue, 30 Jun 2009 00:00:00 +0530 Sat, 30 Sep 2023 10:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=178932 A jurisdictional plea challenging the limitation of a penalty order under section 271(1)(c) can be entertained under Rule 27 of the Income-tax (Appellate Tribunal) Rules even if the cross-objection is delayed, where the issue goes to the root of the matter. The proviso to section 275(1)(a) applies when the relevant first appellate order is passed on or after 1 June 2003, so penalty must be imposed within the statutory period computed from receipt of that appellate order. On the facts stated, the last permissible date was 31 March 2007, but the penalty order was passed on 20 April 2007 and was therefore time-barred. Case-Laws Income Tax Tue, 30 Jun 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=178932