Time Limit for Section 271D Penalty Starts at AO Initiation, Not JCIT Notice Date: ITAT Delhi

Sunil Dandriyal Vs JCIT (ITAT Delhi) The case of Sunil Dandriyal vs JCIT, adjudicated by the Income Tax Appellate Tribunal (ITAT) Delhi, concerns the imposition of penalties under Section 271D of the Income Tax Act, 1961. The central issue revolves around the interpretation of the time limit for passing penalty orders as prescribed by Section 275(1)(c) of the Act. The appellant contested the penalty orders, arguing that they were barred by limitation. Background and Proceedings: The assessee received cash amounts of Rs.10,00,000 and Rs.1,17,50,000 in the assessment years 2009-10 and 2010-11, ...