271D/271E Penalties Time-Barred: Limitation Runs from AO’s Action, Not Addl. CIT Notice

Sanjeev Jai Narain Aeren Vs ACIT (ITAT Delhi) Limitation Starts with AO’s Action, Not Addl. CIT’s Notice: ITAT Quashes 271D/271E Penalties as Time-Barred The Delhi Bench of the Income Tax Appellate Tribunal allowed a batch of eight appeals filed by the assessee and deleted penalties imposed under sections 271D and 271E for AYs 2015-16 to 2018-19, holding that the penalty orders were barred by limitation under section 275(1)(c) of the Income-tax Act. In this case, the assessment orders were completed on 29.12.2022, wherein the Assessing Officer recorded satisfaction and initiated penalty pr...