“Section 275(1)”

Section References (mined)Section 275Section 275(1)152 judgments

The decision most relied on for Section 275(1) is CIT v. Eli Lily & Co. (312 ITR 225), cited in 221 judgments on BharatTax.

Leading authorities on Section 275(1)

CIT v. Eli Lily & Co.

312 ITR 225 · 2009 · Supreme Court

221

citing judgments

Section 195 of the Income Tax Act, which mandates tax withholding on payments to non-residents, applies only to sums that are otherwise chargeable to tax under the Act. Tax withholding provisions are not charging provisions.

CIT v. Indo Nippon Chemicals Co. Ltd.

261 ITR 275 · 2003 · Supreme Court

204

citing judgments

A liability recognized in accordance with the Accounting Standards prescribed by the Institute of Chartered Accountants of India (ICAI) is an allowable expense for income tax purposes.

CIT v. Hissaria Bros.

291 ITR 244 · 2007 · High Court

132

citing judgments

Penalty proceedings for defaults under Sections 269SS and 269T are independent of assessment proceedings; therefore, the limitation period under Section 275(1)(c) for imposing such penalties is not contingent on the completion of appellate quantum proceedings.

Pr. CIT v. Golden Peace Hotels and Resorts (P) Ltd.

124 Taxmann.com 249 · 2021 · Supreme Court

105

citing judgments

A penalty levied under Section 271(1)(c) is not sustainable if the notice issued under Section 274 fails to specifically mention whether the charge relates to concealment of income or furnishing inaccurate particulars of income. The Assessing Officer must specify the exact charge for the penalty to be valid.

Sanjay Sawhney v. Principal Commissioner of Income-tax

116 Taxmann.com 701 · 2020 · High Court

citing judgments

Rule 27 of the ITAT Rules allows a respondent to defend a favourable order of the CIT(A) by raising grounds decided against them, even without filing an appeal or cross-objection. Such issues can be raised orally and for the first time before the Tribunal.

Principal Commissioner of Income-tax\n(Central)-2 v. Mahesh Wood Products (P.) Ltd.

394 ITR 312 · 2017 · High Court

citing judgments

The date of initiation of penalty proceedings for the purpose of Section 275(1)(c) is when the Assessing Officer records a satisfaction or recommends penalty, not the later date when the Joint/Additional Commissioner of Income Tax issues the penalty notice.

CIT v. Hissaria Brothers

386 ITR 719 · 2016 · Supreme Court

citing judgments

The relevant date for determining the limitation period under Section 275(1)(c) for passing penalty orders under Sections 271D and 271E is the date of passing the assessment order.

CIT v. Jai Laxmi Rice Mills Ambala City

64 Taxmann.com 75 · 2015 · Supreme Court

citing judgments

For initiating penalty proceedings under Section 271D or 271E, the Assessing Officer must record satisfaction in the assessment order; non-recording of such satisfaction is fatal to the penalty.

Judgments citing Section 275(1)

3I Infotech Digital Bps Limited Formerly Known As 3I Infotech Bpo Ltd., Delhi vs. ACIT, 25(1), Delhi

In the result, both the appeals filed by the assessee are allowed

ITA 5195/DEL/2024[2014-14]Status: DisposedITAT Delhi24 Jul 2025AY 2014-14

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Shri Om Prakash, Sr. DR

Section 271CSection 275(1)(c)

that the reference in the present case has been made by ACIT, Circle 76(1) on 10.10.2016 and as per the provision of section 275(1)(c), no order imposing of penalty under the provisions of the Act shall be passed beyond the six months from ... that the reference in the present case has been made by ACIT, Circle 76(1) on 10.10.2016 and as per the provision of section 275(1)(c), no order imposing of penalty under the provisions of the Act shall be passed beyond the six months from

M/S Karia Builders, Pune vs. ITO Ward 14(3), Pune

In the result, the appeal filed by the assessee is allowed

ITA 2401/PUN/2024[2017-18]Status: DisposedITAT Pune23 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18 M/S. Karia Builders Ito, Ward 14(3), Pune 402, Konark Indrayu, Kondhwa, Vs. Pune – 411048 Pan: Aadfk5220B (Appellant) (Respondent) Assessee By : Shri Sanket M Joshi Department By : Shri Ramnath P Murkunde Date Of Hearing : 17-07-2025 Date Of Pronouncement : 23-07-2025 O R D E R

For Appellant: Shri Sanket M JoshiFor Respondent: Shri Ramnath P Murkunde

Section 147Section 148Section 269SSection 271DSection 274Section 275(1)Section 296S

fact that the penalty u/s 271D of the Act is invalid as it is time barred in view of the provisions of section 275(1) (c) of the Act. 3. Ld CIT (A) NFAC has erred in confirming penalty levied u/s 271D of the Act without appreciating that the completion ... Counsel for the assessee at the outset submitted that the penalty order is barred by limitation in view of the provisions of section 275(1)(c) of the 5 Act. Referring to the provisions of section 275(1)(c) of the Act, he drew the attention of the Bench

Saluja Construction Company Limited, New Delhi vs. Additional Commissioner of Income Tax, Range-77, Delhi

The appeal is allowed

ITA 3493/DEL/2024[2016-17]Status: DisposedITAT Delhi18 Jul 2025AY 2016-17

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2016-17 Saluja Construction Company Ltd., Vs Addl. Cit, 3, Munirka Marg, Range-77, New Delhi – 110 038. Delhi. Pan: Dels02044A (Appellant) (Respondent) Assessee By : Shri Bhupinder Jit Kumar, Advocate; Shri Raina Majumdar, Advocate; Shri Nikhil Sharma, Advocate & Shri Tushar Kalra, Advocate Revenue By : Shri Mahesh Kumar, Cit-Dr Date Of Hearing : 02.07.2025 Date Of Pronouncement : 18.07.2025 Order Per Anubhav Sharma, Jm:

For Appellant: Shri Bhupinder Jit Kumar, AdvocateFor Respondent: Shri Mahesh Kumar, CIT-DR

Section 201(1)Section 269Section 271Section 271CSection 274Section 275

only the Joint CIT who could have done so. Therefore, for the purpose of limitation under Section 275 (1) (c), the relevant date should be the date on which notice in relation to the penalty proceedings were issued. In the present case, as the Additional CIT issued notice ... 20th March, 2012 was within limitation. 8. We are unable to agree with the above submission of learned Standing counsel for the Revenue. Section 275 (1) (c) reads as under: 275. (1) No order imposing a penalty under this Chapter shall be passed (a).... (b)..... (c) in any other case

Deputy Commissioner of Income Tax, Central Circle-2, Jaipur vs. M/S Kiran Fine Jewellers Pvt Ltd., Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 274/JPR/2025[2017-18]Status: DisposedITAT Jaipur26 Jun 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA Nos.268, 270, 271 & 274/JP/2025 निर्धारण वर्ष / Assessment Years : 2013-14, 2014-15 & 2017-18 Dy. Commissioner of Income बनाम Tax, Central Circle-02, Jaipur Vs. Kiran Fine Jewellers Private Limited F-19, Gautam Marg, Vaishali Nagar, Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AADCK7512P अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by: Shri R. K. Bhatra, CA राजस्व

For Appellant: Shri R. K. Bhatra, CAFor Respondent: Mrs. Alka Gautam, CIT-DR

Section 271DSection 271E

taxmann.com 441 (Rajasthan)/[2017] 397 ITR 650 (Rajasthan) [19-10 2016] as under:- "8. Taking into consideration that under section 275(1)(c) of the Act, it is no doubt that the Commissioner is the competent authority and other contention that the notice was within limitation, in our view ... Additional CIT Issuing notice under Section 271-E of the Act. The Additional CIT ought to have been conscious of the limitation under Section 275 (1) (c), i.e., that no order of penalty could have been passed under Section 271-E after the expiry of the financial year in which

Deputy Commissioner of Income Tax, Jaipur vs. M/S Kiran Fine Jewellers Pvt Ltd., Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 271/JPR/2025[2017-18]Status: DisposedITAT Jaipur26 Jun 2025AY 2017-18

For Appellant: Shri R. K. Bhatra, CAFor Respondent: Mrs. Alka Gautam, CIT-DR

Section 271DSection 271E

Deputy Commissioner of Income Tax, Jaipur vs. M/S Kiran Fine Jewellers Pvt Ltd., Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 270/JPR/2025[2014-15]Status: DisposedITAT Jaipur26 Jun 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri R. K. Bhatra, CAFor Respondent: Mrs. Alka Gautam, CIT-DR

Section 271DSection 271E

Deputy Commissioner of Income Tax, Central Circle-2, Jaipur vs. M/S Kiran Fine Jewellers Pvt Ltd., Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 268/JPR/2025[2013-14]Status: DisposedITAT Jaipur26 Jun 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं./ITA Nos.268, 270, 271 & 274/JP/2025 निर्धारण वर्ष / Assessment Years : 2013-14, 2014-15 & 2017-18 Dy. Commissioner of Income बनाम Kiran Fine Jewellers Private Tax, Vs. Limited Central Circle-02, Jaipur F-19, Gautam Marg, Vaishali Nagar, Jaipur स्थायी लेखा सं./ जीआईआर सं./PAN/GIR No.: AADCK7512P अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by : Shri R. K. Bhatra, CA राजस्व की

For Appellant: Shri R. K. Bhatra, CAFor Respondent: Mrs. Alka Gautam, CIT-DR

Section 271DSection 271E

Manish Sharma, Kota vs. JCIT, Central Circle, Udaipur

In the result, appeal of the assessee is allowed

ITA 619/JODH/2024[2011-12]Status: DisposedITAT Jodhpur25 Jun 2025AY 2011-12

Bench: Date Of Hearing.

Section 132(1)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 250Section 269TSection 271DSection 271E

section 275 in assessee’s case. In this regard, we may submit as under : S.No. Clause of sub- Our submission section(1) of section 275 1 (a) This clause is applicable only when the relevant assessment order or other order is the subject matter of appeal. However, in the present ... sections 271D and 271E might have been initiated, has no relevance for sustaining or not sustaining penalty proceedings, and therefore, clause (a) of section 275(1) cannot be attracted to such proceedings. The position is also upheld by the Hon’ble High Court of Rajasthan in case

Aare Nagaraju, West Godavari vs. Income Tax Officer, Ward-1, Eluru

In the result, appeal filed by the assessee is allowed

ITA 178/VIZ/2025[2013-14]Status: DisposedITAT Visakhapatnam20 May 2025AY 2013-14

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. No.178/Viz/2025 (धनिाारण िर्ा / Assessment Year: 2013-14) Aare Nagaraju, Vs. Income Tax Officer, West Godavari District, Ward-1, Andhra Pradesh-534475. Eluru. Pan: Arupa1167B (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलार्थी की ओर से/ Assessee By : Shri C. Subrahmanyam, Ca प्रत्यार्थी की ओर से / Revenue By : Dr. Aparna Villuri, Sr. Ar सुनिाई की तारीख / Date Of Hearing : 01/05/2025 घोर्णा की तारीख/Date Of : 20/05/2025 Pronouncement O R D E R

For Appellant: Shri C. Subrahmanyam, CAFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 246Section 246ASection 253Section 263Section 264Section 269TSection 271ESection 274Section 275(1)Section 275(1)(c)

lacks legal validity. 2. The subject order levying penalty U/s. 271E of the Act is barred by limitation, as per the provisions of section 275(1)(c) of the Act. Therefore, the impugned order lacks legal validity and should be quashed.” 3. The Learned Authorized Representative (“Ld. AR”) submitted that ... provisions of section 275(1)(c) of the Act, the order for levy of penalty ought to have been passed within the period of six months from the end of the month in which the notice was issued to the assessee. The Ld. AR further submitted that considering the fact

Jacob Thomas, Kozhencherry vs. ACIT, Thiruvalla Range, Thiruvalla

In the result, appeal filed by the assessee stands partly allowed

ITA 138/COCH/2024[AY 2020-2021]Status: DisposedITAT Cochin14 May 2025

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm Assessment Year: 2020-21 Jacob Thomas .......... Appellant 1, Mulamoottil, Kozhencherry 689641 [Pan: Ackpt3269L] Vs. Acit, Ward-1 & Tps, Thiruvalla .......... Respondent Appellant By: Shri Rajakannan, Advocate Respondent By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 20.03.2025 Date Of Pronouncement: 14.05.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)], Dated 27.12.2023 For Assessment Year (Ay) 2020-21. 2. Brief Facts Of The Case Are That The Appellant Is An Individual Deriving Income Under The Head ‘Business’. The Return Of Income For Ay 2020-21 Was Filed On 31.12.2020 Declaring Nil. Against The Said Return Of Income, The Assessment Was Completed By The Acit, Ward -1, Thriuvalla (Hereinafter Called "The Ao") Vide Order Dated 28.09.2022 Passed U/S. 143(3) Of The Income Tax Act, 1961 (The 2 Jacob Thomas Act) At A Total Income Of Rs. 59,34,921/-. While Doing So, The Ao Made Disallowance Of Interest Expenditure Claimed Of Rs. 89,73,412/- U/S. 57 Of The Act. Accordingly, A Show Cause Notice Was Issued U/S. 274 R.W.S 270A Of The Act. The Appellant Had Failed O Respond To The Above Show Cause Notice. In The Circumstances The Ao Had Proceeded With Levy Penalty Of Rs. 57,24,630/- U/S. 270A By Holding That The Appellant Is Guilty Of Misreporting Income.

For Appellant: Shri Rajakannan, AdvocateFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 143(3)Section 270ASection 274Section 275(1)Section 57

137/Coch/2024. In this circumstance the penalty proceeding were remitted to the file of the AO to decide levy of penalty in terms of section 275(1)A of the Act. 8. In the result, appeal filed by the assessee stands partly allowed. Order pronounced in the open court on 14th

Vinod Ramchandra Jadhav, Pune vs. DCIT, CC-2(1), Pune

In the result, the appeal filed by the Revenue is dismissed and the appeal filed by the assessee is partly allowed

ITA 2144/PUN/2024[AY 2010-11]Status: DisposedITAT Pune21 Apr 2025

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2010-11 Dcit, Vinod Ramchandra Jadhav Central Circle 2(1), Vs. Plot No.42-44, Green Park Society, Pune Viman Nagar, Pune – 411014 Pan: Aanpj0592P (Appellant) (Respondent) Assessment Year : 2010-11 Vinod Ramchandra Jadhav Dcit, Plot No.42-44, Green Park Society, Vs. Central Circle 2(1), Pune Viman Nagar, Pune – 411014 Pan: Aanpj0592P (Appellant) (Respondent) Assessee By : Shri Kishor B Phadke Department By : Shri Ajay Kumar Keshari – Cit & Shri Arvind Desai, Addl Cit-Dr Date Of Hearing : 23-01-2025 Date Of Pronouncement : 21-04-2025 O R D E R

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Ajay Kumar Keshari – CIT and Shri Arvind Desai, Addl CIT-DR

Section 132Section 139(1)Section 153ASection 245C(1)Section 245DSection 245D(4)Section 245HSection 271(1)(c)

further hereunder. For the further analysis of issue of limitation period, analysis of end dates emerging from the said sub-clause (c) of section 275(1) is required to be carried out. Now, for reaching the end date of limitation period, it is expedient to determine the correct date ... facts of the case as well as considering the provisions of law. Appellant, in the above table, has simply reproduced specific provisions of section 275(1) of ITA, 1961. However, in this regard, one has to consider the Explanation given at the end of section 275 of ITA, 1961 which

DCIT, CC-2(1), Pune vs. Vinod Ramchandra Jadhav, Pune

In the result, the appeal filed by the Revenue is dismissed and the appeal filed by the assessee is partly allowed

ITA 1307/PUN/2024[2010-11]Status: DisposedITAT Pune21 Apr 2025AY 2010-11

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Ajay Kumar Keshari – CIT and Shri Arvind Desai, Addl CIT-DR

Section 132Section 139(1)Section 153ASection 245C(1)Section 245DSection 245D(4)Section 245HSection 271(1)(c)

Ajay Bakliwal, Kota vs. ACIT, Central Circle, Kota

In the result, the appeal of the assessee is allowed

ITA 1278/JPR/2024[2016-17]Status: DisposedITAT Jaipur11 Apr 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Rajendra Sisodia, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR

Section 132Section 132(1)Section 269SSection 271DSection 274Section 275(1)(c)

default were not linked with the principal assessment proceedings for any specific assessment year but were independent of it. 21. By substituting section 275(1), which became operative from 1-4-1989, the provision of divided cases for the purpose of prescribing limitation for completing penalty proceedings into three categories ... where the penalty proceedings are linked with the assessment proceedings or the other relevant proceedings 26. The expression 'other relevant thing' used in section 275(1)(a) and clause (b) of sub-section (1) of section 275 is significantly missing from clause (c) of section 275(1) to make

Asst.Commissioner of Income Tax, Bandra Kurla Complex Mumbai vs. Devang Ajit Javeri, Mumbai

In the result, appeal of the Revenue is dismissed on aforesaid terms

ITA 4498/MUM/2024[2016-17]Status: DisposedITAT Mumbai29 Jan 2025AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 147Section 153CSection 269Section 269SSection 271DSection 271ESection 275Section 275(1)Section 275(1)(c)

Accordingly, ld. JCIT issued notice on 26/09/2019 and passed the penalty order on 11/03/2020. Accordingly, it has been stated that in terms of Section 275(1)(c), the penalty levied by the ld. JCIT is barred by limitation. 5. After considering the rival submissions and on perusal of the facts ... initiation and levy of penalty. Thus, the initiation happened during the course of proceeding i.e. assessment proceedings u/s.147 r.w.s. 143(3). 6. Section 275(1) states that __ “275. (1) No order imposing a penalty under this Chapter shall be passed: a)……….. b)……….. c) in any other case, after the expiry

Asst. Commissioner of Income Tax, Bandra Kurla Complex vs. Devang Ajit Jhaveri, Mumbai

In the result, appeal of the Revenue is dismissed on

ITA 4497/MUM/2024[2013-14]Status: DisposedITAT Mumbai29 Jan 2025AY 2013-14

Section 143(3)Section 147Section 153CSection 269SSection 271DSection 271ESection 275Section 275(1)Section 275(1)(c)

Accordingly, ld. JCIT issued notice on 26/09/2019 and passed the penalty order on 11/03/2020. Accordingly, it has been stated that in terms of Section 275(1)(c), the penalty levied by the ld. JCIT is barred by limitation. 5. After considering the rival submissions and on perusal of the facts ... JCIT for initiation and levy of penalty. Thus, the initiation happened during the course of proceeding i.e. assessment proceedings u/s.147 r.w.s.143(3). 6. Section 275(1) states that “275. (1) No order imposing a penalty under this Chapter shall be passed: a).......... b).......... c) in any other case, after

Devang Ajit Jhaveri, Mumbai vs. JCIT, Range 17(1), Mumbai

In the result, appeal of the Revenue is dismissed on aforesaid terms

ITA 3510/MUM/2024[2011-12]Status: DisposedITAT Mumbai29 Jan 2025AY 2011-12

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 147Section 153CSection 269Section 269SSection 271DSection 271ESection 275Section 275(1)Section 275(1)(c)

Devang Ajit Jhaveri, Mumbai vs. JCIT, Range 17(1), Mumbai

In the result, appeal of the Revenue is dismissed on

ITA 3509/MUM/2024[2011-12]Status: DisposedITAT Mumbai29 Jan 2025AY 2011-12

Section 143(3)Section 147Section 153CSection 269Section 269SSection 271DSection 271ESection 275Section 275(1)Section 275(1)(c)

Accordingly, ld. JCIT issued notice on 26/09/2019 and passed the penalty order on 11/03/2020. Accordingly, it has been stated that in terms of Section 275(1)(c), the penalty levied by the ld. JCIT is barred by limitation. 5. After considering the rival submissions and on perusal of the facts ... JCIT for initiation and levy of penalty. Thus, the initiation happened during the course of proceeding i.e. assessment proceedings u/s.147 r.w.s.143(3). 6. Section 275(1) states that “275. (1) No order imposing a penalty under this Chapter shall be passed: a)............ b)............ c) in any other case, after

Nilons Enterprises Pvt.Ltd, Pune vs. Ward 2(4), Pune

In the result, appeal of the Assessee is allowed

ITA 1600/PUN/2024[2016-17]Status: DisposedITAT Pune15 Jan 2025AY 2016-17

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

For Appellant: Shri Nikhil PathakFor Respondent: Shri Arvind Desai, Addl. CIT-DR

Section 143(3)Section 269TSection 271E

circumstance of the case and in law, the Tribunal is justified in holding that the penalty order is barred by limitation under Section 275(1) of the Income Tax Act, 1961(the Act) ? (iii) Whether on the facts and in the circumstance of the case and in law, the Tribunal

M/S. Sri. Muthu Cine Service, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-2(1), Bengaluru

ITA 1654/BANG/2024[2016-17]Status: DisposedITAT Bangalore06 Jan 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Respondent: Sri B. S. Balachandran, Advocate

Section 132Section 153CSection 250Section 270ASection 271(1)(c)

outset, the ld. A.R. of the assessee vehemently submitted that all these appeals are barred by limitation as per the provisions contained in section 275(1)(c) of the Act i.e. the penalty orders were not passed within 6 months from the end of the month in which action ... Time barred Time barred Time barred Time barred Time barred 6.1 Before proceeding further, it is apposite here to take note of section 275(1) of the Act for the purpose this case, which reads as under: "Section 275 in The Income Tax Act, 1961 275. [ Bar of limitation

M/S. Sri. Muthu Cine Service, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-2(1), Bangalore

In the result, all these appeals filed by the assessee are allowed

ITA 1632/BANG/2024[2018-19]Status: DisposedITAT Bangalore06 Jan 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

Section 132Section 132(4)Section 139Section 153CSection 250Section 270ASection 271(1)(c)Section 275(1)(c)

outset, the ld. A.R. of the assessee vehemently submitted that all these appeals are barred by limitation as per the provisions contained in section 275(1)(c) of the Act i.e. the penalty orders were not passed within 6 months from the end of the month in which action ... ITANos. 1629 to 1632&1654/Bang/2024 M/s. Sri Muthu Cine Service, Bangalore 6.1 Before proceeding further, it is apposite here to take note of section 275(1) of the Act for the purpose this case, which reads as under: “Section 275 in The Income Tax Act, 1961 275. [ Bar of limitation