Dispute Over Limitation Period for Penalty u/s 271D of Income Tax Act; Reference Date Controversy Arises.

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....Penalty u/s 271D - period of limitation - CIT(A) took the date on which the one year period from the end of the financial year in which the notice was issued as 31/03/2022. - We are unable to understand where from this date has come. Expiry of one year is not relatable to this date either from the date of the assessment order for the assessment year 2017-18 or from the date of issuance of notice u/s 271D of the Act, initiating the proceedings. - AT....