Section 271D & 271E Penalty cannot be levied if assessment is quashed

Ravi Nirman Nigam Ltd Vs ACIT (ITAT Mumbai) Introduction: Penalty u/s. 271D and 271E of the Income Tax Act, 1961 cannot be levied if the assessment proceedings are quashed. Facts of the case: The assessee’s case was reopened u/s. 147 of the Act based on information received from the office of, ACIT, Central Circle-2(4), Ahmedabad. A search was conducted at the premises of Dharmadev Infrastructure Limited, and 36 benami accounts were identified out of which one of them belonged to the asssessee. There were deposits in this account which included cash deposits. In the same reassessment proceed...