Penalty order u/s. 271D/271E beyond 6 months from assessment is barred by limitation

DCIT Vs Ashwani Gupta (ITAT Jaipur) ITAT Jaipur held that penalty orders under section 271D and 271E of the Income Tax Act passed beyond 6 months from end of the month in which assessments were completed is barred by limitation. Accordingly, appeal of revenue stands dismissed. Facts- During proceeding, it was noted that the assessee has taken cash amount of Rs. 3,73,44,474/- from Shri Radha Mohan Totla and repaid Rs. 3,81,68,450/- and the action of the assessee violates the provisions of section 269SS/T and therefore, penalty proceedings was initiated by issuing notice u/s. 274 r.w.s. 271D of...