Penalty proceedings initiated after 6 months from receipt of Adjudicatory Order is time barred

Salora International Ltd. Vs. CIT (Delhi High Court) A plain and textual reading of Section 275(1A) clarifies that the expiry of six months prescribed is to be reckoned from the date of completion of proceedings or from the end of the month in which the order of the CIT(A) or as the case may be the appellate tribunal is received. If the logic of the provision is kept in mind, it is obviously an adjudicatory “order” which culminates in “the proceedings” terminus (i.e. an order that determines inter alia the rights of the parties finally) that is to be deemed a terminus quo for the comp...