Section 271DA Penalty Time Limit Runs from JCIT Notice, Not AO Reference: Karnataka HC

JCIT Vs Ganesh Agarwal (Karnataka High Court) Karnataka High Court Clarifies Limitation under Section 271DA: Six-Month Period Begins from JCIT’s Notice, Not AO’s Reference The Karnataka High Court, in a batch of writ appeals, examined the limitation for imposing penalty under Section 271DA for violation of Section 269ST. The Court held that a proposal/reference made by the Assessing Officer (AO) to the Joint Commissioner (JCIT) is not the initiation of penalty proceedings. Penalty proceedings commence only when the JCIT issues a notice under Section 274. The Court interpreted Secti...