Income tax penalty u/s271(1)(c) imposed while quantum appeal pending held premature; order quashed; s.275 amendment prospective.

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....The dominant issue was whether a penalty order under s.271(1)(c) could be validly passed during pendency of the quantum appeal, and within the limitation framework of s.275. Relying on binding precedent, the Court held that such penalty orders are premature, illegal, and without jurisdiction because the authority must keep penalty proceedings in abeyance until the appellate forum disposes of the appeal, upon which jurisdiction to impose penalty would arise. The Court also held that the Finance Act, 2025 amendment to s.275 applies prospectively to pending matters from 1 April 2025 but does not revive limitation already expired by 31 March 2025. The impugned penalty order was quashed. - HC....