Sec. 271(1)(c) & 275 of the Income-tax Act, 1961 - Penalty - Revenue filed tax appeal against the order passed by ITAT whereby the ITAT deleted the penalty imposed on the Respondent Assessee under section 271(1)(c) of the Act on the basis that it was done after the expiry of the limitation period under section 275(1)(a) of the Act. ITAT followed the decision rendered in case of CIT v. Odeon Builders (P.) Ltd. [2017] 80 taxmann.com 180/247 Taxman 184/393 ITR 27 and held that even for the purposes of the penalty order under section 271(1)(c) read with Section 275(1)(a) the limitation begins to run from the date of the order of the ITAT was served upon the CIT (Judicial). Revenue was unable to dispute that the wording of section 275(1)(a) as far as 'Commissioner of Income Tax' and other officers was identical to the wording in both section 158BFA(3)(c) and section 260A of the Act. High Court dismissed the revenue’s appeal holding that ”the Court finds no error in the ITAT having followed the decision of this Court in Odeon Builders (P.) Ltd. to hold the penalty order in the present case to be barred by limitation“. SLP of revenue also dismissed. - PR. CIT V/s INDIAN SUGAR EXIM CORPORATION LTD. - [2020] 272 TAXMAN 185 (SC)