Penalty under 271D deleted in absence of satisfaction in Assessment Order

Sri Raja Reddy Nalla Vs Add. CIT (ITAT Hyderabad) Assessee had received cash in connection with sale of immovable property . As the amount was more than the specified limit of Rs. 20,000/- , penalty proceedings u/s. 271D were initiated for violating Sec 269SS and penalty order u/s. 271D was passed levying a penalty of Rs. 40,00,000/-. Assesse pleaded, inter alia, ignorance of law before the CIT (A) who confirmed the penalty. On further appeal, assessee raised various grounds. Subsequently the assessee raised an additional ground that the AO has not recorded his satisfaction about initiation of...