https://www.taxtmi.com/highlights?id=97024 Validity of penalty proceedings turned on whether the limitation period in clause (c) of Section 275(1) is residuary; the court held clause (c) is residuary and clauses (a) or (b) apply where penalty proceedings originate from an assessment or revision. Because the penalty under the special provision arose from an assessment linked to admissions during search and was appealed, the court applied the limitation computation under clause (a), measuring six months from receipt of the appellate tribunal order and finding the penalty issued on the final permissible date. Revision proceedings were quashed, so clause (b) did not apply, and the writ was dismissed. en-us Thu, 19 Feb 2026 14:16:19 +0530 Thu, 19 Feb 2026 14:16:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=97024 Validity of penalty proceedings turned on whether the limitation period in clause (c) of Section 275(1) is residuary; the court held clause (c) is residuary and clauses (a) or (b) apply where penalty proceedings originate from an assessment or revision. Because the penalty under the special provision arose from an assessment linked to admissions during search and was appealed, the court applied the limitation computation under clause (a), measuring six months from receipt of the appellate tribunal order and finding the penalty issued on the final permissible date. Revision proceedings were quashed, so clause (b) did not apply, and the writ was dismissed. Highlights Income Tax Thu, 19 Feb 2026 14:16:19 +0530 https://www.taxtmi.com/highlights?id=97024