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Penalty u/s 271D Becomes Time-Barred if Not Imposed Within Six Months of Penalty Action Initiation.

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....Penalty u/s 271D for violation of provisions of section 269SS - Even if it is assumed that the assessing officer has issued a notice u/s 271D on the date of assessment order, i.e., on 31-12-2008, the same would become time barred by 30-06-2009, i.e., within six months from the end of the month in which action for imposition of penalty is initiated - AT....