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    <title>2025 (7) TMI 1591 - ITAT DELHI</title>
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    <description>The ITAT Delhi held that the penalty order under section 271C was barred by limitation as it was passed beyond the six-month period prescribed under section 275(1)(c) from the date the AO referred the matter to the Addl. CIT. Since the penalty order was issued after this limitation period, it was declared invalid. Consequently, the appeals filed by the assessee were allowed, and the penalty order was quashed.</description>
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      <title>2025 (7) TMI 1591 - ITAT DELHI</title>
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      <description>The ITAT Delhi held that the penalty order under section 271C was barred by limitation as it was passed beyond the six-month period prescribed under section 275(1)(c) from the date the AO referred the matter to the Addl. CIT. Since the penalty order was issued after this limitation period, it was declared invalid. Consequently, the appeals filed by the assessee were allowed, and the penalty order was quashed.</description>
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