JCIT issues Penalty Order under Income Tax Act beyond Limitation, Deemed Invalid

The Delhi bench of the Income Tax Appellate Tribunal (ITAT) annulled a penalty, citing a limitation issue. The penalty order, passed on 25.02.2016 by the Joint Commissioner of Income Tax (JCIT), was deemed invalid as it exceeded the deadline of 31.03.2015. \r

The assessee, Turner General Entertainment Networks India Pvt. Ltd, faced penalty under Section 271C for not deducting TDS. The tribunal noted two limitation periods: one ending on 31.03.2014, the other 6 months from penalty initiation. Given the latter, the penalty should've been issued by 31.03.2015. \r

Citing precedent (PCIT vs. JKD Capital & Finlease Ltd), the tribunal dismissed the penalty due to being time-barred, rendering other objections by the assessee moot.