https://www.taxtmi.com/caselaws?id=767327 For section 271D penalty, limitation under section 275(1)(c) runs from initiation of penalty proceedings, namely the first show-cause notice dated 30.03.2021. On that basis, the penalty order dated 25.01.2022 was beyond the prescribed period and therefore time-barred. The CBDT Notification No. 113/2021 and the related transitional relaxation did not save the order on the facts found. The earlier reasoning of the first appellate authority was accepted, and the penalty was treated as invalid and liable to be quashed. en-us Wed, 12 Mar 2025 00:00:00 +0530 Sat, 15 Mar 2025 08:41:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767327 For section 271D penalty, limitation under section 275(1)(c) runs from initiation of penalty proceedings, namely the first show-cause notice dated 30.03.2021. On that basis, the penalty order dated 25.01.2022 was beyond the prescribed period and therefore time-barred. The CBDT Notification No. 113/2021 and the related transitional relaxation did not save the order on the facts found. The earlier reasoning of the first appellate authority was accepted, and the penalty was treated as invalid and liable to be quashed. Case-Laws Income Tax Wed, 12 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767327