Held that limitation as per section 275(1) would start from the date of the initiation of the proceedings by the competent authority, which is on 10 th Feb 2017 ; letter dated 12th April, 2016 by the AO initiating the assessee the proposal for initiating penalty proceedings under section 271D is a process anterior to the initiation of the penalty proceedings the argument that time initiation therefrom was not accepted.  The penalty order dated 28 th July 2017 was not barred by limitation. The penalty was deleted on merit. (AY. 2010-11)