https://www.taxtmi.com/caselaws?id=465078 ITAT allowed the assessee's appeal. It held that penalties imposed u/s 271D and 271E for alleged violations of ss. 269SS and 269T were barred by limitation under s. 275, as the competent authority passed the penalty order on 11.03.2020, beyond both the financial year and six-month statutory periods from initiation, rendering the penalties unsustainable. ITAT further held that the reassessment notice u/s 148 dated 30.07.2022 for A.Y. 2016-17 was invalid and time-barred under the new regime read with TOLA, as it was issued beyond three years without obtaining mandatory approval from the CCIT/PCCIT as required under s. 151. Consequently, the reassessment proceedings and order were quashed as void ab initio. en-us Wed, 29 Jan 2025 00:00:00 +0530 Wed, 03 Dec 2025 16:52:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465078 ITAT allowed the assessee's appeal. It held that penalties imposed u/s 271D and 271E for alleged violations of ss. 269SS and 269T were barred by limitation under s. 275, as the competent authority passed the penalty order on 11.03.2020, beyond both the financial year and six-month statutory periods from initiation, rendering the penalties unsustainable. ITAT further held that the reassessment notice u/s 148 dated 30.07.2022 for A.Y. 2016-17 was invalid and time-barred under the new regime read with TOLA, as it was issued beyond three years without obtaining mandatory approval from the CCIT/PCCIT as required under s. 151. Consequently, the reassessment proceedings and order were quashed as void ab initio. Case-Laws Income Tax Wed, 29 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465078