2025 (7) TMI 668

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.... ORDER PER ANUBHAV SHARMA, JM: These appeals are preferred by the assessee against the orders dated 21.02.2025 of the Ld. Commissioner of Income-tax (Appeals)-26, New Delhi. 2. At the time of hearing, the ld. AR has pointed out that vide grounds No.2 and 3, the assessee has challenged the impugned orders of penalty imposed u/s 271D/271E of the Income Tax Act 1961 (hereinafter referred as the Ac....

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....the end of the month in which action for imposition of penalty is initiated, whichever period expires later." 4. Thus as per section 275(1)(c) of the Act, the penalty proceedings were to be completed later of the two periods, first by 31.03.2023, being the period "after the expiry of the financial year in which the proceedings, in the course of which action for the imposition of penalty has been ....

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....the quantum proceedings were completed by the AO on 17th/18th December, 2008, and the AO initiated the penalty proceedings in December, 2008, thus, the last date by which the penalty order could have been passed is 30th June, 2009. The six months from the end of the month from which action of imposition of penalty was initiated would expire on 30th June, 2009. However, in this case, admittedly, th....