https://www.taxtmi.com/caselaws?id=782036 ITAT Mumbai allowed the assessee's appeal, holding that the penalty imposed u/s 271(1)(c) for A.Y. 2002-03 was time-barred under s. 275(1)(a). It held that limitation in penalty matters must be strictly construed and, once expired, the authority to levy penalty is extinguished. The Department's act of filing Form 36 evidenced receipt of the CIT(A)'s order, fixing the limitation, which expired on 31.03.2008. The penalty order dated 27.10.2023 was therefore void ab initio, and the CIT(A)'s order upholding it was set aside. Merits of the penalty were not examined. en-us Thu, 13 Nov 2025 00:00:00 +0530 Mon, 24 Nov 2025 08:57:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782036 ITAT Mumbai allowed the assessee's appeal, holding that the penalty imposed u/s 271(1)(c) for A.Y. 2002-03 was time-barred under s. 275(1)(a). It held that limitation in penalty matters must be strictly construed and, once expired, the authority to levy penalty is extinguished. The Department's act of filing Form 36 evidenced receipt of the CIT(A)'s order, fixing the limitation, which expired on 31.03.2008. The penalty order dated 27.10.2023 was therefore void ab initio, and the CIT(A)'s order upholding it was set aside. Merits of the penalty were not examined. Case-Laws Income Tax Thu, 13 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782036