https://www.taxtmi.com/caselaws?id=430614 The dominant issue was whether penalty orders under s. 271D for alleged violation of s. 269SS were time-barred under s. 275(1)(c). The HC held that where the AO initiates penalty proceedings in the assessment order, the initiation date in that order is the relevant date for computing limitation; the penalty must be imposed within six months from the end of the month of such initiation. Since initiation occurred in December 2008, the limitation expired on 30 June 2009, but the penalty orders were passed on 29 September 2009. Consequently, the HC upheld the ITAT's deletion of the penalties and decided against the Revenue. en-us Thu, 17 Nov 2022 00:00:00 +0530 Mon, 12 Jan 2026 12:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=430614 The dominant issue was whether penalty orders under s. 271D for alleged violation of s. 269SS were time-barred under s. 275(1)(c). The HC held that where the AO initiates penalty proceedings in the assessment order, the initiation date in that order is the relevant date for computing limitation; the penalty must be imposed within six months from the end of the month of such initiation. Since initiation occurred in December 2008, the limitation expired on 30 June 2009, but the penalty orders were passed on 29 September 2009. Consequently, the HC upheld the ITAT's deletion of the penalties and decided against the Revenue. Case-Laws Income Tax Thu, 17 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=430614