https://www.taxtmi.com/caselaws?id=26528 Section 275 was treated as a machinery provision prescribing the period for imposing penalty under section 271(1)(c), so strict construction applicable to charging and penalty provisions did not alter its operation. The earlier High Court interpretation of section 275 was followed, and the Supreme Court observation relied on by the assessee was not accepted as displacing that binding view. On that basis, the penalty order was not time-barred and the limitation objection failed. en-us Fri, 06 Sep 1985 00:00:00 +0530 Fri, 05 Feb 2010 16:01:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=26528 Section 275 was treated as a machinery provision prescribing the period for imposing penalty under section 271(1)(c), so strict construction applicable to charging and penalty provisions did not alter its operation. The earlier High Court interpretation of section 275 was followed, and the Supreme Court observation relied on by the assessee was not accepted as displacing that binding view. On that basis, the penalty order was not time-barred and the limitation objection failed. Case-Laws Income Tax Fri, 06 Sep 1985 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=26528