https://www.taxtmi.com/caselaws?id=471309 Penalty proceedings must be initiated within a reasonable period, even where the limitation provision specifies only the period for their completion after initiation. The initiating step is the assessing authority's reference to the competent penalty authority, not the later show-cause notice. A purposive construction of the limitation framework prevents indefinite delay and excludes unfettered discretion in commencing penalty action. Delayed initiation rendered the penalty order and consequential demand notice unsustainable, resulting in their quashing. 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=471309 Penalty proceedings must be initiated within a reasonable period, even where the limitation provision specifies only the period for their completion after initiation. The initiating step is the assessing authority's reference to the competent penalty authority, not the later show-cause notice. A purposive construction of the limitation framework prevents indefinite delay and excludes unfettered discretion in commencing penalty action. Delayed initiation rendered the penalty order and consequential demand notice unsustainable, resulting in their quashing. Case-Laws Income Tax Thu, 18 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471309