Assessment order was passed on   30-12-2019 for assessment year 2017-18. Thereafter, the Assessing Officer passed a penalty order under section 271D on 19-8-2021.  Assessee filed writ petition contending that limitation period under section 275(1)(c) had already expired for imposing penalty under section 271D on 31.03.2020 i.e., at end of financial year in which assessment order dated 30.12.2019 was passed and, therefore,  penalty order dated 19-8-2021 was without jurisdiction  Court held that assessment order which gave rise to penalty proceeding was dated 29.03.2004, therefore,  limitation period should had been reconciled in terms of proviso to section 275(1)(a). Further, since the penalty order was not passed before the end of the financial year in which the assessment order was passed, it had to be deferred till appellate authority passed an appellate order in an appeal filed against the relevant assessment order. Since the order by the appellate Commissioner had not yet been passed, ordinarily, passing of penalty order should have awaited period of one year from the end of the month of receipt of order of the appellate authority in terms of proviso to section 275(1)(a). However, since limitation prescribed under section 275(1)(a) which would have otherwise expired during period between 30.03.2020 and 30.03.2022 stood extended till 31.03.2022 due to o COVID-19 pandemic and lockdowns imposed by Notification No. 113/2021 in S.O.3814(E) dated 17.09.2021 issued under section 3(1)(a) of TOLA, 2020, penalty order dated 19-8-2021 was passed within limitation period.(AY. 2017-18)