Bar of limitation for imposing penalties.

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....y has been initiated, are completed, if the relevant assessment or other order is not the subject-matter of an appeal under section 356 or 357 or 362; (b) the order of revision is passed, if the relevant assessment or other order is the subject-matter of revision under section 377 or 378; (c) the order of appeal is received by the jurisdictional Principal Commissioner or Commissi....

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....assessee has been heard, or has been given a reasonable opportunity of being heard; (b) after the expiry of six months from the end of the quarter in which the order under section 356 or 357 or 362 or 365 or 367 is received by the jurisdictional Principal Commissioner or Commissioner or the order of revision under section 377 or 378 is passed. (4) The provisions of section 471(2) shall....