Dismissing the appeal of the revenue, the Court held that more than 11 years had passed since the time the assessment order was passed, and if the date of filing of the return were taken into account, there was a 14 year time gap. The proposal for commencing penalty proceedings was submitted by the Joint Commissioner on March 27, 2019. The record showed that the order under section 271(1)(c) of the Act was passed only on October 31, 2019, which was a date well beyond six months, that expired on September 30, 2019. The order levying a penalty was not valid. Order of Tribunal affirmed. (AY. 2005-06)