Clean slate principle extinguishes uncrystallised operational claims and bars continuation of pending recovery and arbitral proceedings after plan app...
Works contract classification governs composite layout-development contracts where VAT-paid goods are transferred alongside construction and infrastru...
Specified income tax exemption for pollution control body remains conditional on non-commercial activity, unchanged income character, and return filin...
Jurisdictional facts in certificate-of-origin discrepancies can support customs show-cause proceedings, leaving factual explanations for departmental ...
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 4792
Join Channel
TaxTMI 
