No Section 271D Penalty if No Assessment Was Made & No Satisfaction Was Recorded: ITAT Delhi

Ishwar Singh Dabas Vs ITO (ITAT Delhi) The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) allowed the assessee’s appeal and deleted a penalty of ₹65,00,000 imposed under Section 271D of the Income Tax Act for alleged violation of Section 269SS on account of cash received from the sale of immovable property. The assessee challenged the order of the Commissioner of Income Tax (Appeals), which had upheld the penalty. Before the Tribunal, the assessee contended that no assessment had been made for Assessment Year 2016-17 and that no satisfaction had been recorded by the Assessing Offi...