Section 271(1)(c) & 275 of the Income Tax Act, 1961 — Penalty — Concealment Penalty—In terms of provisions of section 275(1)(a), the penalty order should have been passed within six months from the end of the month in which the order of the Tribunal was received by the Department, however,  the order giving effect to the Tribunal's order was dated September 24, 2014, which meant that the order was received by the Department in the month of September  and if September 24,2014 was taken as the date on which the order of the Tribunal was received by the Department penalty under section 271(1)(c) could be levied upto March 31, 2015, however, the AO had levied the penalty under section 271(1)(c) on January 27, 2016, which proved that the penalty order was barred by limitation— Income tax Officer vs. APS Academy [2019] 75 ITR (trib) 563 (Lucknow)