Dismissing the appeal of the revenue the Court held that the reference by the Assessing Officer to the Additional Commissioner was to be treated as the initiating point or initiation of penalty proceedings under section 275. The Assessing Officer by the letter dated November 16, 2016 had admittedly made the reference. The Additional Commissioner issued the show-cause notice only on November 10, 2017, nearly a year later, proposing the levy of penalty under section 271D. The penalty order was passed on February 22, 2018. If the reckoning point was November 16, 2016, it was clear that the proceedings were completed beyond the period of limitation. The order levying penalty under section 271D was  quashed. The court refused to rely on Circular No. 9/DV/2016 dated April 26, 2016 ((2016) 383 ITR (St.) 21). Absence of condonation provision to imply strict adherence to prescribed period. Courts cannot expand statutory timelines.(AY. 2012-13)