Penalty Order Invalidated for Exceeding Time Limit on Section 269ST Violation; Issued Beyond Six-Month Statutory Period.

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....The High Court allowed the assessee's appeal, holding that the order imposing penalty u/s 271DA for contravention of Section 269ST was passed beyond the statutory limitation period prescribed u/s 275(1)(c). The court observed that the penalty proceedings are initiated on the date of receipt of the reference by the competent authority from the Assessing Officer. Since the reference was received on 24.03.2023, the order imposing penalty should have been passed within six months from the end of that month. However, the competent authority delayed the proceedings by almost a year by seeking further documents, which was beyond the prescribed period for passing the penalty order. Consequently, the impugned penalty order was held to be barred by limitation.....