https://www.taxtmi.com/caselaws?id=311746 ITAT PUNE held that penalty proceedings under Section 271E initiated by Addl.CIT were time-barred. The assessment under Section 153A was completed on 30.11.2007, but penalty notice was issued only on 11.03.2010, showing inordinate delay beyond statutory limitation. The tribunal ruled that assessee could support CIT(A)'s order on jurisdictional grounds under Rule 27 of ITAT Rules without filing cross-appeal. Following Hissaria Bros precedent and CBDT Circular dated 26.04.2016, the penalty order was dismissed for being initiated beyond prescribed limitation period under Section 275(1)(c). en-us Fri, 24 Nov 2017 00:00:00 +0530 Thu, 11 Jan 2024 09:26:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311746 ITAT PUNE held that penalty proceedings under Section 271E initiated by Addl.CIT were time-barred. The assessment under Section 153A was completed on 30.11.2007, but penalty notice was issued only on 11.03.2010, showing inordinate delay beyond statutory limitation. The tribunal ruled that assessee could support CIT(A)'s order on jurisdictional grounds under Rule 27 of ITAT Rules without filing cross-appeal. Following Hissaria Bros precedent and CBDT Circular dated 26.04.2016, the penalty order was dismissed for being initiated beyond prescribed limitation period under Section 275(1)(c). Case-Laws Income Tax Fri, 24 Nov 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311746