Penalty Proceedings u/s 271B Barred by Limitation Due to Delay in Initiation After Tribunal Remand.

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....Levy of penalty u/s 271B - no initiation of penalty u/s 271B despite higher gross receipt was available to the AO while passing the original assessment order - penalty proceedings initiated in order passed in remanded matter by Tribunal after a long gap of more than 4 ½ years from the date of original assessment is barred by limitation....