TMI Blog2015 (4) TMI 1102X X X X Extracts X X X X X X X X Extracts X X X X ..... the AO. We find no infirmity with this finding. - Decided in favour of assessee. - ITA No. 751 of 2014 - - - Dated:- 27-4-2015 - MR. S. RAVINDRA BHAT MR. R.K.GAUBA JJ. For the Appellant: Mr. P. Roychaudhury, Advocate For the Respondent: Mr. Salil Aggarwal, Advocate. O R D E R The Revenue is aggrieved by the order of the Income Tax Appellate Tribunal ( ITAT‟) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... T (A) accepted this contention and held inter alia that since the AO initiated the penalty proceedings on 5.12.2011 itself, the penalty order was beyond the period prescribed under Section 275 (1) (c). This finding was confirmed by the ITAT. Learned counsel contends that given the structure and phraseology of Section 271D/271E, the period of six months limitation particularly emphasizing the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (2013) 352 ITR 327 (Raj.) where in an identical facts situation, the Court held that even though the Joint Commissioner is the authority competent to impose penalty under Section 271D the period of limitation for the purposes of such penalty was not to be reckoned from the issue of the first show cause notice by the Joint Commissioner: but the period of limitation was to be reckoned from the dat ..... X X X X Extracts X X X X X X X X Extracts X X X X
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