Discussion on Section 271D Penalty and Section 275 Limitation: Extended Period Not Applicable Without Appellate Proceedings.

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....Penalty u/s 271D - period of limitation u/s 275 - It cannot be said that the relevant assessment or other order was subjected to some appellate proceeding. Consequently, the extended period of limitation of 6 months from the availability of the appellate order, will not be available to the revenue. - AT....