Penalty Quashed as AO Failed to Record Satisfaction Under Section 270A

R D Construction Vs ITO (ITAT Raipur) Penalty on Estimated Labour Disallowance Deleted — Absence of Clear Satisfaction under s.270A Vitiates Levy Raipur ITAT examined the levy of penalty u/s 270A. The assessment was originally completed u/s 143(3) wherein the AO doubted the labour payment register, pointing out absence of names, site details & proper vouchers though thumb impressions & payment receipts existed. AO disallowed the entire labour expenses of Rs.25,58,400/- on an estimated basis & initiated penalty u/s 270A(1) r.w.s 270A(9)(c). On quantum appeal, CIT(A)/NFAC restricte...