https://www.taxtmi.com/caselaws?id=762324 The ITAT Delhi dismissed the Revenue's appeal regarding penalty under section 271E imposed for limitation issues. The Tribunal held that the limitation period for penalty proceedings commences from the AO's initial notice date, not from subsequent notices by JCIT/Additional CIT. Since the AO issued the penalty notice on 31/12/2010 with the assessment order, and Additional CIT issued another notice on 30/06/2011, the penalty had to be imposed before 30/06/2011, not 31/12/2011. The CIT(A) correctly deleted the penalty following judicial precedents and CBDT Circular 9/2016, requiring no tribunal interference. en-us Wed, 27 Nov 2024 00:00:00 +0530 Fri, 29 Nov 2024 08:16:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762324 The ITAT Delhi dismissed the Revenue's appeal regarding penalty under section 271E imposed for limitation issues. The Tribunal held that the limitation period for penalty proceedings commences from the AO's initial notice date, not from subsequent notices by JCIT/Additional CIT. Since the AO issued the penalty notice on 31/12/2010 with the assessment order, and Additional CIT issued another notice on 30/06/2011, the penalty had to be imposed before 30/06/2011, not 31/12/2011. The CIT(A) correctly deleted the penalty following judicial precedents and CBDT Circular 9/2016, requiring no tribunal interference. Case-Laws Income Tax Wed, 27 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762324