https://www.taxtmi.com/caselaws?id=797792 Penalty proceedings and consequential orders under Section 271DA were time-barred under the unamended Section 275(1)(c). Two coordinate-bench approaches identified either the Assessing Officer's reference or the Joint Commissioner's Section 274 notice as the point at which proceedings begin. On either approach, where assessment orders were passed in March 2024, the applicable six-month limitation period expired on 30 September 2024. A show-cause notice issued on 12 December 2024 was therefore beyond limitation, rendering the penalty orders and related demand notices unsustainable. en-us Thu, 20 Aug 2026 00:00:00 +0530 Thu, 27 Aug 2026 08:28:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797792 Penalty proceedings and consequential orders under Section 271DA were time-barred under the unamended Section 275(1)(c). Two coordinate-bench approaches identified either the Assessing Officer's reference or the Joint Commissioner's Section 274 notice as the point at which proceedings begin. On either approach, where assessment orders were passed in March 2024, the applicable six-month limitation period expired on 30 September 2024. A show-cause notice issued on 12 December 2024 was therefore beyond limitation, rendering the penalty orders and related demand notices unsustainable. Case-Laws Income Tax Thu, 20 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797792