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Practical Example of Time barred cases for Penalty notice under 271(1)(c)

SURANA (PROPRIETOR)     28 October 2020

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I am looking out for some practical example for Limitation of Time for Penalty Notice under section  271(1)(c) .

if would be great if you can provide some example with dates to understand different limitation.


For Example

CIT (A) dismissed the appeal filed by the Assessee and order was passed on 18.05.2018

The Order was challenged in ITAT and it was partly allowed by ITAT , order dated 19.12.2018

AO show cause notice  u/s 271(1)(C) notice on 03.03.2020.

"Penalty under section 271(1)(c) of the Income-tax Act, 1961 was initiated in your case for the
assessment year 2011-12.
It is further noticed that the ld.CIT(A) has dismissed the appeal filed by you against the
addition/disallowances made against which the penalty under section 271(1)(c) of the Act
was initiated.
You are, therefore, requested to show cause as to why the penalty should not be levied
under section 271(1)(c) of the Act in your case.
Your submission in this regard must reach the office of the undersigned on or before
11/03/2020, failing which further proceedings shall be undertaken in accordance with the
material facts as on records."

Now in this particular case the CIT (A) order was passed on 18.05.2018

and even Tribunal has passed the order on 19.12.2018

isnt this case is time barred under section 275?


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