Income Tax Penalty Quashed: ITAT Invalidates Order Due to Lack of Recorded Satisfaction by Assessing Officer.

The ITAT quashed the penalty proceedings under section 271D of the Income Tax Act, initially confirmed by the CIT(A), due to the assessing officer's failure to record the necessary satisfaction for initiating the penalty. The absence of this recorded satisfaction was deemed critical, as per legal requirements and relevant judgments. Consequently, the appellant's appeal was allowed, and the penalty order was invalidated. The decision was delivered in open court on 24/09/2021, favoring the appellant.

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Issues involved:
1. Appeal against penalty order under section 271D of the Income Tax Act.

Analysis:
1. The appellant challenged the penalty order confirmed by the CIT(A) based on the grounds mentioned in the appeal memo. The assessing officer did not record the satisfaction required for initiating the penalty under section 271D, as pointed out by the Ld.AR. Citing a Supreme Court decision, it was argued that without such recorded satisfaction, penalty proceedings would not be valid.

2. The CIT(A) upheld the order of the assessing officer, leading to the appellant's appeal before the ITAT. The Ld. AR reiterated the absence of recorded satisfaction in the assessment order as the basis for quashing the penalty proceedings.

3. The ITAT considered the arguments from both parties and reviewed the assessment order, noting the lack of recorded satisfaction by the assessing officer for initiating the penalty under section 271D. Emphasizing the importance of this recording as per the law and relevant judgments, the ITAT deemed the absence of satisfaction as fatal to the penalty proceedings. Consequently, the penalty initiated by the assessing officer and confirmed by the CIT(A) was ordered to be quashed, thereby allowing the appellant's appeal.

4. The decision was pronounced in open court on 24/09/2021 by the ITAT, thereby concluding the matter in favor of the appellant.

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