https://www.taxtmi.com/caselaws?id=467825 Penalty under Section 271D was held time-barred because limitation under Section 275(1)(c) was computed from the Assessing Officer's reference to the penalty authority, not from the later show-cause notice. Where two views on initiation were possible, the Tribunal adopted the view favourable to the assessee and followed the High Court ruling relied on before it. The plea to exclude time for rehearing on change of incumbent was rejected because Explanation (i) to Section 275 applies only where the assessee seeks rehearing under the proviso to Section 129, and no such request was shown. The penalty order was quashed. en-us Thu, 28 Aug 2025 00:00:00 +0530 Sat, 04 Apr 2026 15:07:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467825 Penalty under Section 271D was held time-barred because limitation under Section 275(1)(c) was computed from the Assessing Officer's reference to the penalty authority, not from the later show-cause notice. Where two views on initiation were possible, the Tribunal adopted the view favourable to the assessee and followed the High Court ruling relied on before it. The plea to exclude time for rehearing on change of incumbent was rejected because Explanation (i) to Section 275 applies only where the assessee seeks rehearing under the proviso to Section 129, and no such request was shown. The penalty order was quashed. Case-Laws Income Tax Thu, 28 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467825