https://www.taxtmi.com/caselaws?id=471763 Unappealed reassessment orders place the limitation for penalties under section 271(1)(c) within section 275(1)(c). The ordinary deadline expired on 30 June 2020, while pandemic-related relief under TOLA and applicable circulars extended it only until 30 September 2021. General limitation extensions granted during the pandemic could not enlarge this special statutory limitation regime. Once the prescribed period expired, the tax authority lacked jurisdiction to impose the penalty. Consequently, a penalty order issued on 23 November 2021 was time-barred and liable to be quashed. en-us Mon, 16 Mar 2026 00:00:00 +0530 Wed, 16 Sep 2026 19:00:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471763 Unappealed reassessment orders place the limitation for penalties under section 271(1)(c) within section 275(1)(c). The ordinary deadline expired on 30 June 2020, while pandemic-related relief under TOLA and applicable circulars extended it only until 30 September 2021. General limitation extensions granted during the pandemic could not enlarge this special statutory limitation regime. Once the prescribed period expired, the tax authority lacked jurisdiction to impose the penalty. Consequently, a penalty order issued on 23 November 2021 was time-barred and liable to be quashed. Case-Laws Income Tax Mon, 16 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471763