Tribunal Must Follow Delhi High Court Precedent on Limitation Period Start u/s 271D of Income Tax Act.

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....Penalty u/s. 271D - From which date counting of limitation start - Reference of matter by AO or notice by Joint CIT - Though the contention of the Revenue seems to be plausible. - However, being the sub-ordinate tribunal, we are bound to follow the decision of the Hon’ble Delhi High Court.....