VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.275 as substituted: penalty limitation now runs from the end of the QUARTER
CBDT Circulars & InstructionsCuts both wayss.275s.274s.274(2)s.246s.246As.253s.263s.264s.260As.261s.129

Statutory position — s.275 as substituted: penalty limitation now runs from the end of the QUARTER

I am checking whether a penalty order is out of time. Is the old six-months-from-the-end-of-the-month rule still the test?

I am checking whether a penalty order is out of time. Is the old six-months-from-the-end-of-the-month rule still the test?

No. Section 275 has been substituted, and under the substituted provision no penalty order under Chapter XXI may be passed after the expiry of six months from the end of the QUARTER in which the triggering event occurs, with five separate triggers in clauses (a) to (e). The financial-year limb and the month-end limb of the old sub-section (1), and the old proviso giving one year from the end of the financial year in which the appellate order was received, are gone.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2025-04-01, reported as Income-tax Act, 1961, section 275 as substituted by the Finance Act, 2025 (Act No. 7 of 2025), with effect from 1 April 2025. It bears on section 275, section 274, section 274(2), section 246, section 246A, section 253, section 263, section 264, section 260A, section 261, section 129 of the Income Tax Act 1961, in Penalty, How Tax Law Is Read and Appeals matters.

Still good law. In force from 1 April 2025. The substituted text and its commencement were both verified this pass on the department's own page /w/section-275-64, which carries a 'Year: 2025' stamp and the footnote 'Sub. by Act No. 7 of 2025, w.e.f. 1-4-2025', and the text agrees word for word with a Tribunal reproduction recovered independently through five /docfragment/ retrievals. The date the substitution takes effect was cross-checked against the department's own Year 2024 (No. 2) page for the same section, which still prints the pre-substitution text. No decision construing the substituted section was located; it is too new. No 'Year: 2026' page for the section was found among the suffixes probed, so a further amendment by a 2026 Finance Act is not excluded — check before advising on a penalty order passed in or after April 2026.

Why it matters

Every limitation computation carried over from the older authorities will now be wrong at the margins, and limitation is the ground that most often defeats a penalty. Three changes matter in practice. First, the clock runs from the end of a QUARTER, not the end of a month or of a financial year, so the outer date shifts. Second, the triggers are now expressly separated: completion of the proceedings where there is no appeal, receipt of the CIT(A) or JCIT(A) order where there is one and no further appeal, receipt of the Tribunal's order where there is, the passing of the revision order, and — the residuary case — the ISSUE OF THE NOTICE for imposition of penalty. That last clause matters for the procedural penalties in this slice: a section 272A, 271FA, 271H or 271J penalty is not integrally linked to an assessment, so it will usually fall in clause (e) and the clock will run from the penalty notice. Third, the exclusion for a court stay now runs to the date the certified copy of the vacating order is received by the jurisdictional Principal Commissioner or Commissioner, which is later than the old formulation.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

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