Income Tax Act limits penalty order issuance to 6 months after Tribunal's order receipt by Chief Commissioner.

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....Period of limitation for passing the penalty order u/s 275(1)(a) - the limitation period for the levy of penalty will be as provided for under s. 275(1)(a), i.e., six months from the end of the month in which the order of the Tribunal is received by the Chief CIT - AT....