https://www.taxtmi.com/caselaws?id=471310 Penalty proceedings commence when the assessing authority refers the matter to the competent penalty authority, not when a show-cause notice is issued. Although Section 275(1)(c) fixes the period for completing penalty proceedings, delay and laches prevent the Revenue from initiating proceedings after an unreasonable delay. The limitation principle therefore restricts any unfettered discretion to defer commencement. On these principles, the delayed penalty order and consequential demand were treated as invalid and quashed in favour of the assessee. en-us Thu, 18 Sep 2025 00:00:00 +0530 Fri, 28 Aug 2026 20:38:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471310 Penalty proceedings commence when the assessing authority refers the matter to the competent penalty authority, not when a show-cause notice is issued. Although Section 275(1)(c) fixes the period for completing penalty proceedings, delay and laches prevent the Revenue from initiating proceedings after an unreasonable delay. The limitation principle therefore restricts any unfettered discretion to defer commencement. On these principles, the delayed penalty order and consequential demand were treated as invalid and quashed in favour of the assessee. Case-Laws Income Tax Thu, 18 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471310