No Section 271D Penalty if AO Not Recorded Satisfaction: ITAT Delhi

Anglican India Consultancy Pvt. Ltd. Vs ACIT (ITAT Delhi) The appeal was filed against the order of the Commissioner of Income Tax (Appeals)-I, New Delhi, for Assessment Year 2011-12, confirming the levy of penalty under Section 271D of the Income-tax Act for alleged violation of Section 269SS. The assessee had filed its return declaring an income of ₹16,04,765. During assessment proceedings under Section 143(3), the Assessing Officer observed cash deposits and withdrawals in the assessee’s bank account. The assessee explained that cash withdrawals amounted to ₹1,08,45,348, whereas cash ...