The assessment was completed u/s 143(3) on 28 -10-2011 .  After  four year  the  AO, in an internal communication dated 9-9-2013 addressed to Additional Commissioner of Income-tax, wrote that penalty should be imposed on assessee for failure to deduct tax at source qua AY 2007-08 .  On 9-11-2017 a show cause notice (SCN) was issued under section 274 for initiating penalty proceedings under section 271C . The  Assessee contended that proceedings triggered via said SCN were barred by limitation .  However the Assessing Officer  fixed the hearing for levy of the penalty . The petitioner filed the writ petition challenging that the notice was barred by limitation . Allowing the petition the Court held that the  notice issued nine years after the end of the relevant financial year was barred by limitation . Accordingly the order was quashed . ( AY. 2007 -08 )