Limitation for penalty proceedings under sections 271D and 271E of the Income tax Act, 1961

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....or penalty proceedings under sections 271D and 271E of the Income tax Act, 1961 - reg. The issue whether the limitation for imposition of penalty under sections 271D and 271E of the Income tax Act, 1961, (hereinafter referred to as the Act) is determined under section 275(1)(a) or section 275(1)(c) of the Act, has given rise to considerable litigation. 2. The Hon'ble Delhi High Court in ....

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....ty proceedings under section 271D and 271E of the Act is governed by the provisions of section 275(1)(c) of the Act. Therefore, the limitation period for the imposition of penalty under these provisions would be the expiry of the financial year in which the proceedings, in the course of which action for the imposition of penalty has been initiated, are completed, or six months from the end of the ....