Penalty u/s 271E not maintainable if notice is issued after the period specified in Section 275(1)(c)

Delhi High Court held In the case of Principal CIT vs. JKD Capital & Finlease Ltd. that in terms of the provision u/s 275 (1) (c), there are two distinct periods of limitation for passing a penalty order, and one that expires later will apply. One is the end of the financial year in which the quantum proceedings are completed in the first instance. The second possible date is expiry of six months from the month in which the penalty proceedings were

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