Dismissing the appeal of the Revenue the Court held that since the action for imposition of penalty was taken when the assessment order was passed i.e., 31st Dec., 2010, the second limb of s. 275(1)(c) suggests that the period would extend by another six months i.e., till 30th June, 2011. On the facts of the case  the assessment order was passed on 31st Dec., 2010. Penalty order passed on 30th Dec., 2011 was barred by limitation-Contention that the AO could not have triggered the penalty proceedings and hence, the limitation would commence, as prescribed, only from the date when the Jt. CIT issued the notice on 13th June, 2011 is not sustainable. If the limitation period is connected to when the concerned officer issues notice, then the Revenue can extend the period of limitation, way beyond the timeline prescribed in s. 275(1)(c). No substantial question of law.  (AY.  2008-09)