Allowing the petition the Court held that ,the entire proceedings initiated for imposition of penalty under section 271E for the alleged violation of section 269T was barred by limitation as prescribed under section 275(1)(c). Between the issuance of the show-cause notice on November 27, 2014 and the date of passing of the final orders on September 21, 2016, the limitation period prescribed under section 275(1)(c) had expired. The final order under section 271E was passed on September 21, 2016 much beyond the period of six months, since the order on rectification under section 154 was passed on November 26, 2015, though the law did not give any condonation for a pending rectification application filed. The order was quashed and set aside. ( AY. 2009-10 to 2011-12)