Section 271E penalty Initiation without recording reasons unsustainable: Madras HC

GPR Textiles P. Ltd. Vs ACIT (Madras High Court)

Madras High Court held that the Assessment Officer has not recorded the reasons for arriving at a subjective satisfaction to initiate penalty proceedings under Section 271E of the Act, which is mandatory. Thus, order set aside.

Facts- These writ petitions have been filed by the petitioner challenging the impugned orders passed by the 1st Respondent u/s 271D of the Income Tax Act, 1961 dated 29.04.2024.

Notably, initially assessment proceedings were initiated against the petitioner on 29.09.2021 and ther

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