66. Time limit for imposition of penalty or levy of interest

(1) No order for imposing penalty shall be passed–

(a) after expiry of two years from the end of the year in which the relevant assessment or rectification order is passed; and

(b) if the assessment or rectification order is subject matter of appeal, revision or other proceeding, after expiry of two years from the end of the year in which the order in appeal, revision or other proceeding is passed.

(2) (a) Subject to the provisions of clause (b) of sub–section (1), no order for levy of interest shall be passed –

(i) after expiry of two years from the end of the year in which relevant assessment or rectification order is passed; and

(ii) if the assessment or rectification order is the subject matter of appeal, revision or other proceeding, after expiry of two years from the end of the year in which the order in appeal, revision or other proceeding is passed.

(b) No order for levy of interest in the case of recovery of demand shall be passed after expiry of two years from the end of the year in which such demand in full is recovered or adjusted or partly recovered and partly adjusted.

Explanation. – In computing the period of limitation under this section, the period during which the proceeding for imposition of penalty or levy of interest remains stayed or restrained under the orders of any competent authority or court shall be excluded.