Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
Constitutional judicial review permits challenges to ECIRs and connected money-laundering proceedings where coercive action affects fundamental intere...
The ITAT Delhi held that the levy of penalty u/s 271D without valid satisfaction for alleged violation u/s 269SS is not justified. The AO must record satisfaction in the assessment order u/s 143(3) to initiate penalty proceedings u/s 271D. In this case, the AO failed to record satisfaction for penalty u/s 271D for the relevant assessment years. The tribunal referred to the case law of Jai Laxmi Rice Mills and concluded that penalty u/s 271D was not warranted. Consequently, the penalty imposed u/s 271D for both assessment years was deleted, and the appeals of the assessee were allowed.
The ITAT Delhi held that the levy of penalty u/s 271D without valid satisfaction for alleged violation u/s 269SS is not justified. The AO must record satisfaction in the assessment order u/s 143(3) to initiate penalty proceedings u/s 271D. In this case, the AO failed to record satisfaction for penalty u/s 271D for the relevant assessment years. The tribunal referred to the case law of Jai Laxmi Rice Mills and concluded that penalty u/s 271D was not warranted. Consequently, the penalty imposed u/s 271D for both assessment years was deleted, and the appeals of the assessee were allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4780
Join Channel
TaxTMI 
