Section 271D Penalty Quashed as Time-Barred in Absence of Assessment: ITAT Chennai

B. Anand Babu Vs DCIT (ITAT Chennai) Penalty u/s 271D Quashed as Time-Barred under Section 275(1)(c) The Hon’ble ITAT, Chennai held that the impugned penalty orders passed u/s 271D for AYs 2016-17, 2017-18 and 2019-20 were vitiated and barred by limitation under Section 275(1)(c) of the Act. The Tribunal noted that no assessment proceedings were framed, and therefore the first limb of Section 275(1)(c) was not applicable. In the absence of assessment, the date of initiation of penalty proceedings was held to be 21.04.2022, being the date on which the AO made a reference to the Addl./JCIT. Co...