ITAT Quashes Section 271D Penalty as AO Failed to Record Satisfaction

Ram Lubhaya Jassal Vs ACIT (ITAT Amritsar) The appeal was filed by the assessee against the order of the Commissioner of Income Tax (Appeals) dated 29 June 2017, which had confirmed the penalty imposed under Section 271D of the Income-tax Act. Before the Tribunal, the assessee contended that the Assessing Officer had failed to record the mandatory satisfaction for initiating penalty proceedings under Section 271D in the assessment order. The assessee relied upon the Supreme Court’s decision in Jai Lakshmi Rice Mills (64 taxmann.com 75), wherein it was held that if the required satisfacti...