https://www.taxtmi.com/caselaws?id=441408 Penalty proceedings under the Income-tax Act cannot be kept open indefinitely where Section 275(1)(c) does not specify the commencement point for the six-month limit. The Delhi HC treated the word "initiated" as referring to the date on which the penalty proposal is made, not the later issue of the show-cause notice, because a contrary reading would let the Revenue choose the limitation start date. It also applied the principle that, when the statute is silent, penalty action must be taken within a reasonable period. On these facts, the proposed penalty was issued many years after the assessment and return, so the proceedings were held time-barred. en-us Thu, 27 Jul 2023 00:00:00 +0530 Wed, 11 Feb 2026 12:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=441408 Penalty proceedings under the Income-tax Act cannot be kept open indefinitely where Section 275(1)(c) does not specify the commencement point for the six-month limit. The Delhi HC treated the word "initiated" as referring to the date on which the penalty proposal is made, not the later issue of the show-cause notice, because a contrary reading would let the Revenue choose the limitation start date. It also applied the principle that, when the statute is silent, penalty action must be taken within a reasonable period. On these facts, the proposed penalty was issued many years after the assessment and return, so the proceedings were held time-barred. Case-Laws Income Tax Thu, 27 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=441408