https://www.taxtmi.com/caselaws?id=791209 Penalty proceedings under section 271C are governed by the limitation period in section 275(1)(c), which runs from the end of the month in which penalty action is initiated. Strict construction applies in fiscal matters, and a later show-cause notice does not postpone limitation where the penalty reference has already been made. On the facts, the penalty order was passed beyond the prescribed period, so the penalty was time-barred and unsustainable. en-us Mon, 04 May 2026 00:00:00 +0530 Thu, 07 May 2026 07:08:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791209 Penalty proceedings under section 271C are governed by the limitation period in section 275(1)(c), which runs from the end of the month in which penalty action is initiated. Strict construction applies in fiscal matters, and a later show-cause notice does not postpone limitation where the penalty reference has already been made. On the facts, the penalty order was passed beyond the prescribed period, so the penalty was time-barred and unsustainable. Case-Laws Income Tax Mon, 04 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791209