Section 271(1)(c) and 275(1)(a) of the Income Tax Act, 1961 — Penalty — Appeal effect order having been passed by AO on 22nd May, 2017, the six month period of limitation under section 275(1)(a) will begin to run from that date ,hence, penalty order passed by AO on 26th April 2018, passes beyond six months was barred by limitation under section 275(1)(a). claim that ITO, Judicial-II received the copy of the order dt. 27th Jan, 2017 of the Tribunal only on 31st October, 2017 was not sustainable — GE Energy Parts Inc vs. Deputy Commissioner of income tax [2019] 310 CTR (Delhi) 729