Initiating Penalty Without Recording Satisfaction Vitiates section 271D Proceedings

DCIT Vs Subramaniam Thanu (ITAT Chennai) Section 271D penalty proceeding cannot be initiated if AO fail to record his satisfaction before initiating penalty penalty proceeding in respect of violation of provisions of section 269SS of Income Tax Act,  1961. Assessing Officer has to record his satisfaction before initiating penalty under section 271D of the Act in respect of violation of the provisions of section 269SS of the Act. In this case, the assessment order was passed on 30.12.2017 and reference was made by the Assessing Officer to the Addl. CIT on 14.03.2021 to initiate penalty proceed...