Penalty proceedings initiated after 4.5 years not sustainable

Amit Sabharwal Vs ITO (ITAT Delhi) The issue under consideration is whether the penalty proceeding initiated after 4.5 years from date of original assessment order is justified in lawand also when order was silent about the levy of penalty under section 271B? ITAT states that as per the provisions of section 275(1)(c), no order imposing a penalty under this Chapter shall be passed in any case, after the expiry of the financial year in which the proceedings, in the course of which action for the imposition of penalty has been initiated, are completed or six months from the end of the month in w...