Section 271D Penalty Quashed Due to Failure to Record Section 269SS Satisfaction

Grandhi Sri Venkata Amarendra Vs JCIT (Andhra Pradesh High Court) The writ petition challenged proceedings dated 23.11.2023 passed under Section 271D of the Income Tax Act, 1961, levying a penalty of Rs.1,50,00,000/-. The petitioner contended that no satisfaction was recorded in the assessment order regarding initiation of penalty under Section 271D. The case arose from a search and seizure operation under Section 132 in the case of M/s Usha Bala Group and V.V. Balakrishna Rao. Certain documents relating to the petitioner were found, and proceedings under Section 153C were initiated. The petit...