https://www.taxtmi.com/caselaws?id=757770 ITAT Delhi dismissed Revenue's appeals regarding penalty under section 272A(2)(g) for delayed TDS certificate issuance. The tribunal held penalty orders dated 29.9.2009 and 27.5.2016 were barred by limitation under section 275(1)(c), as they exceeded the prescribed six-month period from penalty initiation. Following precedent in Sunil Dandriyal case, limitation period commenced from AO's initiation of penalty proceedings in assessment order, not from subsequent show cause notices. On merits, tribunal relied on Dhir Global Industries judgment, noting TDS certificates can only be issued after deposit with government, making certificate delay dependent on deposit timing. Penalty deleted entirely. en-us Tue, 13 Feb 2024 00:00:00 +0530 Fri, 30 Aug 2024 18:02:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757770 ITAT Delhi dismissed Revenue's appeals regarding penalty under section 272A(2)(g) for delayed TDS certificate issuance. The tribunal held penalty orders dated 29.9.2009 and 27.5.2016 were barred by limitation under section 275(1)(c), as they exceeded the prescribed six-month period from penalty initiation. Following precedent in Sunil Dandriyal case, limitation period commenced from AO's initiation of penalty proceedings in assessment order, not from subsequent show cause notices. On merits, tribunal relied on Dhir Global Industries judgment, noting TDS certificates can only be issued after deposit with government, making certificate delay dependent on deposit timing. Penalty deleted entirely. Case-Laws Income Tax Tue, 13 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757770