Penalty order passed beyond 6 months from date of ITAT's order confirming additions was barred by limitation

INCOME TAX: Where assessment order making addition to income of assessee was confirmed by Tribunal on 27-1-2017 and order giving effect to order of Tribunal was passed on 22-5-2017, impugned penalty order dated 26-4-2018 under section 271(1)(c) being passed much after limitation period of six months as prescribed under section 275(1)(a) from 22-5-2017, was invalid on ground of limitation

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