2015 (4) TMI 1102

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....Revenue is aggrieved by the order of the Income Tax Appellate Tribunal („ITAT‟) dated 16.05.2014 passed in ITA 3794/Del/2013. It contends that the ITAT‟s view that the penalty proceedings under Section 271E were barred is erroneous. For AY 2009-10, the Assessing Officer completed the assessment in the respondent/assessee‟s case on 5.12.2011. In the course of these procee....

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.... Section 271D/271E, the period of six months limitation particularly emphasizing the words "whichever is later" would commence only from the date when the appropriate and competent officer authorized to impose penalty issues notice. It was submitted that the ITAT‟s findings are erroneous because in this case the notice was issued by the Joint Commissioner on 12.03.2012 and the penalty impose....