Penalty u/s 271E Exceeds Limitation Period; Initiation Date Misinterpreted as Notification to JCIT or SCN Issuance.

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....Penalty u/s. 271E - period of limitation - There is no dispute that the period of limitation is required to be examined as per Section 275(1)(c) - it is futile to contend that the date of initiation of proceedings is the date on which the JCIT receives intimation from the AO or the date on which the JCIT issues SCN to the Assessee - AO having initiated the penalty proceedings in assessment order dated 24.3.2016 and imposed on 27.1.2017 - bared by limitation....