Section 271D Penalty Cannot Be Levied Without Recorded Satisfaction: Gujarat HC

PCIT Vs Parivar Television Private Limited (Gujarat High Court) The Gujarat High Court considered a Tax Appeal under Section 260-A of the Income Tax Act, 1961, challenging the order of the Income Tax Appellate Tribunal (ITA No. 1738/AHD/2016) for the block period 01.04.1995 to 19.12.2001. The main questions were whether the Tribunal was justified in deleting a penalty under Section 271D amounting to Rs. 2.79 crore, whether it erred in not upholding the CIT(A)’s findings, and whether the Tribunal incorrectly based its decision on the absence of recorded satisfaction in the assessment order ra...