Dismissing the appeal of the revenue the Court held that Tribunal was justified in holding that for purposes of penalty order under section 271(1)(c) read with section 275(1)(a) limitation begins to run from date of order of appellate tribunal was served upon Commissioner (Judicial). Followed CIT v. Odeon Builders (P.) Ltd. (2017) 393 ITR 27 / 247 Taxman  184 (FB)  (Delhi) (HC)   where in the Court  categorically held that in the context of Section 260A of the Act, the limitation period for filing an appeal against an order of the TAT would begin to run immediately upon a copy of the order being received by the CIT (Judicial). (AY. 2009-10)