https://www.taxtmi.com/caselaws?id=445098 Delhi HC held that penalty proceedings u/s 271E were time-barred as the limitation period u/s 275(1)(c) expired by 30.06.2011. The court ruled that revenue authorities cannot extend the limitation period at their discretion by delaying issuance of notice u/s 274. Although the assessing officer obtained prior approval from ACIT before 31.12.2010 and the penalty decision was embedded in the assessment order, the notice was issued only on 13.06.2011, which was beyond the prescribed limitation period. The appeal was decided in favor of the assessee. en-us Mon, 11 Sep 2023 00:00:00 +0530 Mon, 16 Feb 2026 11:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445098 Delhi HC held that penalty proceedings u/s 271E were time-barred as the limitation period u/s 275(1)(c) expired by 30.06.2011. The court ruled that revenue authorities cannot extend the limitation period at their discretion by delaying issuance of notice u/s 274. Although the assessing officer obtained prior approval from ACIT before 31.12.2010 and the penalty decision was embedded in the assessment order, the notice was issued only on 13.06.2011, which was beyond the prescribed limitation period. The appeal was decided in favor of the assessee. Case-Laws Income Tax Mon, 11 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445098