https://www.taxtmi.com/caselaws?id=765431 Delhi HC dismissed petition challenging penalty proceedings u/s 271DA for being beyond limitation period prescribed in s.275(1)(c). Court held that six-month limitation period commences from reference date (08.04.2024) when AO decided to initiate penalty proceedings, not from assessment order date (28.03.2024). Since penalty proceedings were initiated within eleven days of assessment completion, delay was reasonable and within prescribed limitations. Court emphasized that while limitation periods cannot be extended arbitrarily, inordinate delays require examination of whether reasonable period standard applies. en-us Mon, 20 Jan 2025 00:00:00 +0530 Thu, 16 Jul 2026 11:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765431 Delhi HC dismissed petition challenging penalty proceedings u/s 271DA for being beyond limitation period prescribed in s.275(1)(c). Court held that six-month limitation period commences from reference date (08.04.2024) when AO decided to initiate penalty proceedings, not from assessment order date (28.03.2024). Since penalty proceedings were initiated within eleven days of assessment completion, delay was reasonable and within prescribed limitations. Court emphasized that while limitation periods cannot be extended arbitrarily, inordinate delays require examination of whether reasonable period standard applies. Case-Laws Income Tax Mon, 20 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765431