Notice u/s 274 needs to be issued before limitation period prescribed u/s. 275(1)(c)

PCIT Vs Thapar Homes Limited (Delhi High Court) Delhi High Court held that the notice under Section 274 of the Income Tax Act should have been issued before the period of limitation as prescribed under section 275(1)(c) of the Income Tax Act. Facts- Revenue has preferred the present writ contesting that whether the Income Tax Appellate Tribunal misdirected itself on facts and in law, in deleting the penalty imposed under Section 271E of the Income Tax Act, 1961 on the ground that it was beyond the period of limitation, as prescribed under Section 275 (1)(c) of the Act. Notably, assessment orde...