Limitation for 271D/271E Penalty Runs from AO’s Satisfaction, Not JCIT Notice

Devang Ajit Jhaveri Vs JCIT (ITAT Mumbai) Limitation for 271D/271E penalties starts from the AO’s satisfaction recorded in assessment order, not from JCIT’s notice Mumbai ITAT has delivered a significant ruling   where it quashed penalty orders passed u/s 271D &  271E on the ground of limitation &  also struck down a reassessment notice issued for AY 2016-17 as invalid for want of proper sanction under the amended regime of Section 151. Tribunal also dismissed a Revenue appeal on account of low tax effect, thereby providing clarity on three distinct issues relating to penalty, ...