Penalty Order Under Section 271D Invalid as Time-Barred, Exceeding Six-Month Limitation Period Under Section 275(1)(c)

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....The ITAT held that the penalty order under section 271D was time-barred. The AO issued reference to the JCIT on 31.07.2019, and following Mahesh Wood Products, the penalty order should have been passed within six months (by 31.01.2020). Since the JCIT passed the order on 28.02.2020, it exceeded the prescribed limitation period under section 275(1)(c). The Tribunal determined this rendered the penalty order invalid. The second contention regarding non-submission of demand notice alongside the penalty order was deemed academic since the assessee had already succeeded on the first ground. The appeal was decided in favor of the assessee.....