Time limit for initiation of penalty proceedings u/s 271D & 271E to be reckoned from date of JCIT Notice

Brief of the case:

• The Hon’ble Kerala High Court in the case of Grihalakshmi Vision Vs. ADIT held that the penalty proceeding under Sec 271D and 271E can be initiated by Joint commissioner only and the limitation period of six months to be reckoned from the end of month of initiation of penalty proceedings by Joint Commissioner and not from the date of assessment order.
• Thus, even if the assessment order providing that the penalty proceedings being initiated the time limits as prescribed u

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