TMI BlogBar of limitation for imposing penalties - Section 275X X X X Extracts X X X X X X X X Extracts X X X X ..... from the end of the financial year in which the order of the Joint Commissioner (Appeals) or to the Commissioner (Appeals) is received by the Principal Chief Commissioner or Chief Commissioner or [Omitted w.e.f. 01.10.2024] Principal Commissioner or Commissioner, whichever period expires later Situation (i)(b) In a case, where further appeal has been filed to appellate tribunal [Section 275(1)(a)] Time limit for passing penalty order Penalty order can be passed by AO On or before the expiry of the financial year in which the assessment proceedings are completed, or On or before the expiry of six months from the end of the month in which order of Appellate Tribunal is received by the Principal Chief Commissioner or Chief Commissioner or [Omi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or before the expiry of 6 months from the end of the month in which penalty proceedings were initiated by Commissioner (Appeals). whichever is later Where the relevant assessment order is subject matter of revision u/s 263. Situation (i) Where an appeal against order u/s 263 is filed to ITAT Time limit for passing penalty order Penalty order can be passed by PCIT or CIT On or before the expiry of the financial year in which order u/s 263 was passed by PCIT/CIT, or On or before the expiry of 6 months from the end of the month in which order of ITAT is received by PCIT or CIT. whichever is later Situation (ii) Where no appeal is filed against order u/s 263. Time limit for passing penalty order Penalty order can be passed by the PCIT or CIT o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s for the imposition of penalty may be passed on the basis of assessment as revised by giving effect to such order of the Joint Commissioner (Appeals) or Commissioner (Appeals) or, the Appellate Tribunal or the High Court, or the Supreme Court or order of revision under section 263 or section 264. However, no order of imposing or enhancing or reducing or cancelling penalty or dropping the proceedings for the imposition of penalty shall be passed- - (a) unless the assessee has been heard, or has been given a reasonable opportunity of being heard; - (b) after the expiry of 6 months from the end of the month in which the order of the Joint Commissioner (Appeals) or Commissioner (Appeals) or the Appellate Tribunal or the High Court or the Supre ..... X X X X Extracts X X X X X X X X Extracts X X X X
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