Penalty u/s 271-E - The Add. CIT ought to have been conscious of the limitation u/s 275(1)(c), i.e.,...

Penalty u/s 271-E - The Add. CIT ought to have been conscious of the limitation u/s 275(1)(c), i.e., that no order of penalty could have been passed u/s 271-E after the expiry of the financial year in which the quantum proceedings were completed or beyond six months after the month in which they were initiated, whichever was later. - HC .....

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