2026 (9) TMI 1248

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....the assessee is directed against the order of Ld. Commissioner of Income Tax (Appeals)/NFAC, Delhi (for short, "CIT(A)") dated 10.12.2025 passed u/sec. 250 of the Income Tax Act, 1961 (for short, "Act") which is arising out of penalty order dated 17.04.2025 passed u/sec. 271(1)(c) of the Act for the Assessment Year (A.Y.) 2013-14. 2. Grievance of the assessee is against the levy of penalty u/se....

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....he action for imposition of penalty has been initiated, are completed, whichever period expires later. Learned counsel for the assessee submitted that in the light of the said provision, the last date for passing of penalty order is 31.03.2025 whereas penalty order has been passed on 17.04.2025 which is barred by limitation. In support, he placed reliance on the following case-laws:- (i) ....

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....the Act on the ground of limitation goes to the root cause of the proceedings. I find that in the instant case, assessment proceedings have been initiated in the assessment order framed u/sec. 143(3) r.w.s 263 of the Act dated 19.09.2024. Though, intimation of the said assessment order has been given to the assessee vide letter dated 01.10.2024, however, there is no dispute to the fact that penalt....