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of <h1>Delhi High Court Rules Penalty Proceedings u/s 271C Time-Barred Due to Delayed Order Issuance.</h1> The Delhi High Court addressed whether penalty proceedings under Section 271C of the Income Tax Act were time-barred. The key issue was determining the initiation date of these proceedings: either when the Assessing Officer referred the case to the Joint Commissioner of Income Tax (JCIT) on 25.09.2014 or when the JCIT issued a show cause notice on 04.08.2015. The Court ruled that proceedings were initiated on the earlier date, aligning with its previous decision in a similar case. Since the penalty order was issued beyond the six-month limitation period from the initiation date, it was deemed time-barred under Section 275(1)(c).
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