Assessee filed its return of income declaring certain loss. Tax audit report furnished by assessee had reported that assessee had not deducted certain amount as tax at source which was deductible by assessee. Assessing Officer made a reference to Joint Commissioner (TDS) on 25-9-2014. Joint Commissioner (TDS) issued show cause notice on 4-8-2015  He, thereafter proceeded to pass order dated 25-2-2016, levying penalty under section 271C. Commissioner (Appeals) deleted penalty on ground that it was barred by limitation. Dismissing the appeal of the Revenue the Court held that  penalty proceedings were initiated on receipt of reference on 25-9-2014 and not on issuance of show cause notice on 4-8-2015 and, therefore, order of penalty passed by Joint Commissioner (TDS) is  barred by limitation. (AY. 2011-12)