SC Upholds HC View That Failure to Record Satisfaction Bars Section 271D Penalty

JCIT Vs Grandhi Sri Venkata Amarendra (Supreme Court of India) The matter arose from penalty proceedings initiated under Section 271D of the Income Tax Act, 1961. The Assessing Officer had completed assessment proceedings under Section 143(3) read with Section 153C pursuant to a search and seizure operation under Section 132 in the case of M/s Usha Bala Group and V.V. Balakrishna Rao. Certain documents relating to the assessee were found. Notices were issued under Sections 143(2) and 142(1), and the assessee consistently denied having accepted any cash loans, stating that all loans were throug...