Held that under section 275(1)(c) of the Act, no order for imposing penalty shall be passed after the expiry of the financial year in which the proceedings and in which action for imposition of penalty has been initiated are completed, or six months from the end of the month in which action for imposition of penalty is initiated, whichever expires later. There are two specific periods of limitation for passing a penalty order and the one that expires later should be the outward limit of time by which the penalty order should be passed. In the assessee’s case, the penalty proceedings were initiated by order dated December 14, 2017, and the penalty order could not have been passed later than March 31, 2018. The second possible time limit is expiry of six months from the month in which the penalty proceedings were initiated. The penalty proceedings having been initiated by the Assessing Officer in the month of December 2017 the last date by which the penalty order could have been passed was June 30, 2018. The later of the two dates was June 30, 2018. The penalty order having been passed on December 7, 2018, it was barred by limitation of time.(AY. 2015-16)