ITAT Deletes Sections 271D and 271E Penalties as Assessment Order Lacked Satisfaction

Smt. S.B.Patil Vs JCIT (ITAT Bangalore) The appeals were filed by the assessee against the orders of the Commissioner of Income Tax (Appeals), Belgaum, challenging the levy of penalties under Sections 271D and 271E of the Income-tax Act, 1961. Along with the original grounds, the assessee also raised additional grounds contending that the initiation of penalty proceedings was legally invalid because no satisfaction had been recorded during the assessment proceedings. The assessee submitted that the additional grounds involved a pure question of law requiring no fresh verification of facts. Rel...