Unexplained Delay in Penalty u/s 271C Raises Validity Concerns Due to Limitation Period Lapse.

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....Penalty imposed u/s 271C - Bar of limitation for imposing penalties - Period for commencement of limitation prescribed in terms of the second limb of clause (c) of sub-section (1) of Section 275 of the Act would commence either from 2013 or 2014, there is a period of unexplained substantial delay, as the SCN, concededly, was issued only on 09.11.2017. - HC....