Levy of penalty u/s. 271D without recording any satisfaction untenable: Andhra Pradesh HC

Grandhi Sri Venkata Amarendra Vs JCIT (Andhra Pradesh High court) Andhra Pradesh High Court held that levy of penalty under section 271D of the Income Tax Act untenable since AO didn’t record any satisfaction to the effect that provisions of section 269SS of the Income Tax Act are violated. Facts- During the search proceedings in the case of M/s. V.V.Balakrishna Rao, certain incriminating documents relating to the petitioner were found. AO concluded that the petitioner had financial transaction with Balakrishna Rao, outside the books and outside banking channels for the subject assessment ye...