Limitation Period for Penalty Orders u/s 271(1)(a) Must Be Fixed and Certain per Income Tax Act.

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....Penalty u/s 271(1)(a) - limitation to pass penalty order - Limitation, it goes without saying, has to be fixed and certain. Section 275(1A) speaks of giving effect to the orders passed by the appellate forums. It does not impose any condition whether to levy or not to levy the penalty.....