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2016 (9) TMI 449 - CALCUTTA HIGH COURTPenalty u/s 271D - validity of notice - period of limitation - Held that:- Once it is realized that the proceedings were initiated on 26th December, 2006 when the notice was issued by the Assessing Officer, the period of limitation necessarily expired on 30th June, 2007 whereas the order imposing penalty was passed on 21st September, 2007. No elaborate reasoning is required to demonstrate that the order is hit by limitation. In that view of the matter, the substituted question is answered in the negative and against the revenue.
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