Section 271D cannot be imposed after expiry of larger period of limitation

Jagdish Chandra Suwalka Vs JCIT (ITAT Jaipur)

ITAT observed that the provisions contained u/s 275(1)(a)are not applicable on the facts of present case for the reason that undisputedly no appeal has been filed against the assessment order passed on 28.12.2017. Therefore, it cannot be said that the relevant assessment or other order was subjected to some appellate proceeding. Consequently, the extended period of limitation of 6 months from the availability of the appellate order, will not be available to the revenue. But other

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