2013 (7) TMI 85

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..... iod of limitation was to be reckoned from the date of issue of first show cause for initiation of such penalty proceedings - Present proceedings hit by the bar of limitation - Tribunal not committed any error in setting aside the order of penalty - Following decision of Commissioner of Income Tax vs. Jitendra Singh Rathore [2013 (3) TMI 222 - RAJASTHAN HIGH COURT] - Decided in favour of assessee. .....

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..... to be reckoned from the date of issue of first show cause for initiation of such penalty proceedings. For the purpose of present case, as observed hereinabove, for the proceedings having been initiated on 25th March, 2003, the order passed by the Jt.CIT under s. 271D on 28th May, 2004 was hit by the bar of limitation. The CIT(A) and the Tribunal have, thus, not committed any error in setting aside .....

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