https://www.taxtmi.com/caselaws?id=795149 For penalties under Section 271DA, limitation under Section 275(1)(c) begins when the Joint Commissioner issues a Section 274 notice, not when the Assessing Officer sends a proposal. Although no express initiation deadline applies, the Joint Commissioner must decide whether to issue notice within six months from the end of the month in which the proposal is received; delayed initiation makes the proceedings time-barred. Sections 271DA and 274 require a reasonable opportunity of hearing before penalty, but do not require detailed allegations in the notice or prior recorded satisfaction by the Joint Commissioner. Penalties initiated and completed within the applicable periods remain valid. en-us Tue, 07 Jul 2026 00:00:00 +0530 Fri, 17 Jul 2026 08:37:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795149 For penalties under Section 271DA, limitation under Section 275(1)(c) begins when the Joint Commissioner issues a Section 274 notice, not when the Assessing Officer sends a proposal. Although no express initiation deadline applies, the Joint Commissioner must decide whether to issue notice within six months from the end of the month in which the proposal is received; delayed initiation makes the proceedings time-barred. Sections 271DA and 274 require a reasonable opportunity of hearing before penalty, but do not require detailed allegations in the notice or prior recorded satisfaction by the Joint Commissioner. Penalties initiated and completed within the applicable periods remain valid. Case-Laws Income Tax Tue, 07 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795149