Section 271D Penalty Invalid if AO fails to record satisfaction: Rajasthan HC

Sunil Agrawal Son Of Ghanshyam Agarwal Vs ACIT (Rajasthan High Court) Rajasthan High Court addressed multiple writ petitions filed by Sunil Agrawal and others challenging penalty notices issued under Sections 271D and 271E of the Income Tax Act, 1961. The case primarily involved a reassessment order dated March 12, 2024, which added amounts under Sections 69A and 69C based on search proceedings. Subsequent penalty notices under Section 271E were issued, leading the petitioner to argue that such penalties were invalid as the assessing officer (AO) failed to record satisfaction for initiating pe...