ITAT Deletes Section 271D Penalty as AO Did Not Record Satisfaction

Bhowmick Raj Singh Vs JCIT (ITAT Raipur) The appeal before the Income Tax Appellate Tribunal (ITAT), Raipur arose from the order of the Commissioner of Income Tax (Appeals), which had upheld a penalty of ₹27 lakh under Section 271D for the alleged violation of Section 269SS of the Income-tax Act for Assessment Year 2010-11. The assessee also raised additional grounds challenging the validity of the penalty on the basis that the Assessing Officer (AO) had not recorded satisfaction for initiating penalty proceedings under Section 271D in the assessment order and that the penalty was barred by ...