(c)in a case where the assessment is the subject-matter of an appeal under section 357 or 362,—(i)after the expiry of the financial year in which the proceedings, in the course of which action for the imposition of penalty has been initiated, are completed; or(ii)six months from the end of the financial year in which the order of the Commissioner (Appeals) or the Appellate Tribunal is received by the jurisdictional Principal Commissioner or Commissioner,whichever period expires later;