https://www.taxtmi.com/caselaws?id=471762 Section 271D penalties for contravening cash-loan restrictions are subject to the limitation period under Section 275(1)(c), consistent with CBDT Circular No. 10/2016. Where no assessment proceedings were initiated or completed for the relevant assessment years, the limitation limb linked to completion of proceedings does not apply. The Assessing Officer's reference to the Addl./Joint Commissioner initiates penalty proceedings; a subsequent Faceless Penalty Unit notice does not alter that date. Penalty orders passed after the resulting six-month deadline were barred by limitation and invalid. en-us Mon, 22 Dec 2025 00:00:00 +0530 Wed, 16 Sep 2026 19:00:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471762 Section 271D penalties for contravening cash-loan restrictions are subject to the limitation period under Section 275(1)(c), consistent with CBDT Circular No. 10/2016. Where no assessment proceedings were initiated or completed for the relevant assessment years, the limitation limb linked to completion of proceedings does not apply. The Assessing Officer's reference to the Addl./Joint Commissioner initiates penalty proceedings; a subsequent Faceless Penalty Unit notice does not alter that date. Penalty orders passed after the resulting six-month deadline were barred by limitation and invalid. Case-Laws Income Tax Mon, 22 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471762