https://www.taxtmi.com/caselaws?id=465178 ITAT Ahmedabad allowed the assessee's appeal and quashed the penalty order passed u/s 271(1)(c) as time-barred under s. 275(1)(a). It held that the penalty proceedings, being integrally connected with the assessment, had to be completed within the prescribed limitation, i.e., by 30-11-2003, computed from the date the quantum order of the Tribunal was received by the CIT. The Tribunal ruled that the pendency or disposal of a miscellaneous application in the quantum appeal does not extend or suspend the limitation period, as no such exclusion is envisaged in the Explanation to s. 275. Consequently, the penalty order dated 28-01-2005 was held without jurisdiction and invalid. en-us Thu, 07 Oct 2010 00:00:00 +0530 Tue, 09 Dec 2025 18:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465178 ITAT Ahmedabad allowed the assessee's appeal and quashed the penalty order passed u/s 271(1)(c) as time-barred under s. 275(1)(a). It held that the penalty proceedings, being integrally connected with the assessment, had to be completed within the prescribed limitation, i.e., by 30-11-2003, computed from the date the quantum order of the Tribunal was received by the CIT. The Tribunal ruled that the pendency or disposal of a miscellaneous application in the quantum appeal does not extend or suspend the limitation period, as no such exclusion is envisaged in the Explanation to s. 275. Consequently, the penalty order dated 28-01-2005 was held without jurisdiction and invalid. Case-Laws Income Tax Thu, 07 Oct 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465178