Levy of penalty u/s 271D without any assessment proceedings is invalid

Umakant Sharma Vs JCIT (ITAT Indore)

ITAT Indore held that the penalty levied u/s 271D of the Income Tax Act without any assessment proceedings in the case of the assessee is not valid and liable to be quashed.

Facts- There was a search and seizure action in case of M/s. S. R. Ferro Alloys Group. During the course of search and seizure certain documents were impounded from Shri Ramesh Chand Upadhya showing the cash loan given to various persons including assessee. Accordin

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