https://www.taxtmi.com/caselaws?id=791409 For limitation under section 275(1)(c), initiation of penalty proceedings is treated as the Assessing Officer's reference that triggers penalty action, not the later notice issued by the penalty authority. On that interpretation, the penalty order was passed after the prescribed time limit had already expired and was therefore time-barred. Where two interpretations are possible, the view favourable to the assessee was preferred. The penalty under section 271D was consequently held unsustainable. en-us Fri, 08 May 2026 00:00:00 +0530 Mon, 11 May 2026 09:50:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791409 For limitation under section 275(1)(c), initiation of penalty proceedings is treated as the Assessing Officer's reference that triggers penalty action, not the later notice issued by the penalty authority. On that interpretation, the penalty order was passed after the prescribed time limit had already expired and was therefore time-barred. Where two interpretations are possible, the view favourable to the assessee was preferred. The penalty under section 271D was consequently held unsustainable. Case-Laws Income Tax Fri, 08 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791409