Penalty limitation under section 275(1)(c) runs from the show-cause notice where proceedings arise outside assessment proceedings.

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....Penalty proceedings under section 271D that are not initiated during an assessment or other proceeding fall outside the first alternative limitation period in section 275(1)(c). In that situation, the show-cause notice constitutes the latest point at which action to impose the penalty is regarded as initiated. The penalty order must therefore be made within six months from the end of the month in which that notice is issued. An order made after that deadline is time-barred and cannot sustain the penalty.....