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The ITAT held that for penalty u/s 271D for contravention of section 269SS, recording satisfaction by AO is mandatory. Citing Jaya Laxmi Rice Mills case, it emphasized the need for satisfaction to initiate penalty proceedings u/s 271D, similar to u/s 271E. The Supreme Court decision in Jai Laxmi Rice Mills reinforced this requirement. The penalty order by the Income Tax Commissioner was quashed as AO failed to record satisfaction. Consequently, CIT(A)-NFAC's order was set aside, and the penalty u/s 271D was deleted, allowing the assessee's appeal.
The ITAT held that for penalty u/s 271D for contravention of section 269SS, recording satisfaction by AO is mandatory. Citing Jaya Laxmi Rice Mills case, it emphasized the need for satisfaction to initiate penalty proceedings u/s 271D, similar to u/s 271E. The Supreme Court decision in Jai Laxmi Rice Mills reinforced this requirement. The penalty order by the Income Tax Commissioner was quashed as AO failed to record satisfaction. Consequently, CIT(A)-NFAC's order was set aside, and the penalty u/s 271D was deleted, allowing the assessee's appeal.
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