Tribunal held that the penalty proceedings under section 271D were initiated during reassessment by issuing a show-cause notice dated 17-8-2022, but the penalty order was passed on 29-3-2023 beyond the limitation period prescribed under section 275(1)(c); the same was barred by limitation and not sustainable. (AY. 2017-18)
Karia Builders. v. ITO (2025) 214 ITD 161 (Pune) (Trib.)
S.271D: Penalty-Takes or accepts any loan or deposit-Limitation-Penalty proceedings under section 271D were initiated during reassessment by issuing a show-cause notice on 17-8-2022-Penalty order was passed on 29-3-2023 beyond the limitation period under section 275(1)(c)-Penalty was barred by limitation and was not sustainable. [S. 148, 269SS, 275(1)(c)]
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