https://www.taxtmi.com/caselaws?id=471308 Penalty proceedings must be initiated within a reasonable period and completed within the prescribed limitation period. The assessing officer's reference to the competent penalty authority, rather than the later issuance of a show-cause notice, triggers the relevant action. Revenue discretion cannot permit indefinite delay because that would defeat the purpose of limitation law. Where initiation is delayed beyond a reasonable period, the doctrine of delay and laches applies, rendering the penalty order and consequential demand unsustainable and liable to be quashed. 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=471308 Penalty proceedings must be initiated within a reasonable period and completed within the prescribed limitation period. The assessing officer's reference to the competent penalty authority, rather than the later issuance of a show-cause notice, triggers the relevant action. Revenue discretion cannot permit indefinite delay because that would defeat the purpose of limitation law. Where initiation is delayed beyond a reasonable period, the doctrine of delay and laches applies, rendering the penalty order and consequential demand unsustainable and liable to be quashed. Case-Laws Income Tax Thu, 18 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471308