Penalty Time-Barred When AO’s Satisfaction Recorded Before Notice: ITAT Chennai

DCIT Vs Jayapriya Company (ITAT Chennai) Chennai Bench of the Income Tax Appellate Tribunal held that the penalty order issued under section 271D of the Income Tax Act, 1961 was barred by limitation as per section 275(1)(c). The assessee’s assessment order was passed on 30.12.2022, with prior approval of the Additional CIT, and contained specific satisfaction recorded by the Assessing Officer for alleged violation of section 269SS. Applying CBDT Circular No. 10/2016 dated 26.04.2016, the Tribunal observed that the period of limitation for imposing penalty must be reckoned from the date of re...