No Satisfaction, No Penalty: ITAT Delhi Quashes 271DA Penalty

ACIT Vs Seven Seas Hospitality Pvt Ltd (ITAT Delhi) No Satisfaction, No Penalty: ITAT Delhi Quashes 271DA Penalty Following Supreme Court’s Jai Laxmi Rice Mills ITAT Delhi quashed the Section 271DA penalty after holding that the Assessing Officer failed to record mandatory satisfaction in the assessment order, a requirement firmly established by the Supreme Court in Jai Laxmi Rice Mills. Treating Section 271DA as pari materia with Sections 271D and 271E, the Tribunal ruled that penalties initiated without such recorded satisfaction are invalid in law, making the Revenue’s appeal unsustaina...