Suo moto disallowance sought by the assesee with regard to the provisions of section 40(a)(ia) of the Act. The AO passed assessment order. The JC submitted a proposal for levying penalty for failure to deduct tax at source. The AO issued a notice almost 11 years after the assessment order and 14 years after the return was filed. On appeal, the Hon’ble Delhi High Court observed that the word used in the provision of section 275(1)(c) is ‘initiated’, which is an act which would get triggered on the date when the proposal is made. This rationale ties in with the view taken by the coordinate Bench of the High Court in the case of Clix Capital Services (P.) Ltd. [2023] 149 taxmann.com 279 (Delhi) (HC). Hence, it was held that the action of the revenue is barred by limitation.(AY. 2005-06)