https://www.taxtmi.com/caselaws?id=799143 Penalty proceedings under section 271D, where no assessment or related order exists during which they were initiated, fall under the six-month limb of section 275(1)(c). The relevant financial-year limb does not apply in that situation. The show-cause notice issued under section 274 read with section 271D constituted initiation of penalty action at the latest. As the penalty order was issued after expiry of six months from the end of that month, it was time-barred, quashed, and the sustained penalty was deleted. en-us Fri, 11 Sep 2026 00:00:00 +0530 Thu, 17 Sep 2026 07:52:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799143 Penalty proceedings under section 271D, where no assessment or related order exists during which they were initiated, fall under the six-month limb of section 275(1)(c). The relevant financial-year limb does not apply in that situation. The show-cause notice issued under section 274 read with section 271D constituted initiation of penalty action at the latest. As the penalty order was issued after expiry of six months from the end of that month, it was time-barred, quashed, and the sustained penalty was deleted. Case-Laws Income Tax Fri, 11 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799143