Limitation Period for Penalty Proceedings Begins with Assessment Order: Delhi HC

PCIT Vs Thapar Homes Limited (Delhi High Court)

Delhi High Court addressed the issue of penalty limitation under the Income Tax Act in the case of PCIT vs Thapar Homes Ltd. The case pertained to the assessment year 2008-09, where the Assessing Officer (AO) initiated penalty proceedings under Sections 271AAA, 271D, and 271E. The primary issue was whether the Income Tax Appellate Tribunal (ITAT) erred in ruling that the penalty imposed under Section 271E was barred by limitation as per Section 275(1)(c). The court examined whether the limitation period should be counted from

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