Time limit for issue of penalty proceeding on issues unrelated to income assessment

Delhi High Court rules in favour of the assessee- time limitation for “initiation” of penalty proceedings Under Section 275 on issues unrelated to assessment of income (such as for s. 269SS/ 269T & TDS defaults) runs from the date on which the AO wrote a letter recommending the issuance of the Show Cause Notice to the ACIT, and not from the date mentioned in the Show Cause Notice. Thus, orders are illegal, being barred by time limitation. ITA No. 786/2016 order dated 05.05.2017. Full Text of the High Court Judgment / Order is as follows:- 1. These are two appeals filed by the...