Delay in Dispatching ITAT Order to CIT Cannot Circumvent Penalty Limitation Period u/s 271(1)(c.

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....Penalty u/s 271(1) (c) - limitation - service to CIT (Judicial) - the mandatory period of limitation u/s 275(1)(a) cannot be sought to be defeated by delaying the dispatch of the relevant order of the ITAT to the concerned ‘jurisdictional’ CIT - what is relevant is when the CIT(Judicial) representing the Department before the ITAT received the order - the impugned penalty orders are clearly without jurisdiction....