Section 271E Penalty Cannot Survive Without Recorded Satisfaction: SC

CIT Vs Jai Laxmi Rice Mills Ambala City (Supreme Court of India) The Supreme Court considered whether penalty proceedings under Section 271D of the Income Tax Act are independent of assessment proceedings in relation to Assessment Years 1991-92 and 1992-93. The dispute arose after an ex parte assessment order dated 26.02.1996 assessed the assessee’s income and recorded satisfaction that the provisions of Section 269SS had been contravened, leading the Assessing Officer to initiate penalty proceedings under Section 271E. The assessee challenged the assessment, and the Commissioner of Inco...