https://www.taxtmi.com/caselaws?id=59202 For limitation under s. 275(1)(c), the ITAT held that penalty proceedings were initiated by the assessment order dated 21-3-1994, not by the AO's earlier information-seeking letter; the penalty order dated 28-9-1994 was therefore within time and not barred. On merits of penalties under ss. 271D/271E for alleged violation of ss. 269SS/269T, the ITAT held that reliance on a third party's search statement and a computer floppy was impermissible where cross-examination was denied, the statement was later retracted/denied, and no corroborative material (e.g., promissory note/hundi or entries in books) established cash borrowing or repayment; both penalties were accordingly cancelled and the appeals allowed. en-us Tue, 30 Apr 2002 00:00:00 +0530 Tue, 23 Dec 2025 19:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59202 For limitation under s. 275(1)(c), the ITAT held that penalty proceedings were initiated by the assessment order dated 21-3-1994, not by the AO's earlier information-seeking letter; the penalty order dated 28-9-1994 was therefore within time and not barred. On merits of penalties under ss. 271D/271E for alleged violation of ss. 269SS/269T, the ITAT held that reliance on a third party's search statement and a computer floppy was impermissible where cross-examination was denied, the statement was later retracted/denied, and no corroborative material (e.g., promissory note/hundi or entries in books) established cash borrowing or repayment; both penalties were accordingly cancelled and the appeals allowed. Case-Laws Income Tax Tue, 30 Apr 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59202