https://www.taxtmi.com/caselaws?id=786795 Whether the penalty order was time-barred turned on which clause of Section 275(1) governed limitation. The court held clause (a) applies where the penalty proceedings originate in an assessment order that is the subject-matter of appeals; clause (c) is residuary and inapplicable. Because the penalty was initiated in the assessment order and that assessment was under appeal culminating in an appellate order received in December 2021, limitation under clause (a) ran to six months from receipt of the appellate order and therefore the penalty dated 30.06.2022 fell within time; the writ was dismissed. en-us Fri, 06 Feb 2026 00:00:00 +0530 Thu, 19 Feb 2026 07:58:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786795 Whether the penalty order was time-barred turned on which clause of Section 275(1) governed limitation. The court held clause (a) applies where the penalty proceedings originate in an assessment order that is the subject-matter of appeals; clause (c) is residuary and inapplicable. Because the penalty was initiated in the assessment order and that assessment was under appeal culminating in an appellate order received in December 2021, limitation under clause (a) ran to six months from receipt of the appellate order and therefore the penalty dated 30.06.2022 fell within time; the writ was dismissed. Case-Laws Income Tax Fri, 06 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786795