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The ITAT set aside the penalty imposed under section 271DA of the Act due to the absence of recorded satisfaction in the quantum assessment order, a mandatory prerequisite for levying such penalty. Drawing analogy from the Supreme Court's ruling in a case concerning section 271E, where penalties were quashed for lack of recorded satisfaction, the tribunal held that the same principle applies to penalties under section 271DA. Consequently, the penalty imposed without the requisite satisfaction recording was held invalid. The appeal filed by the assessee was allowed, and the penalty under section 271DA was cancelled.
The ITAT set aside the penalty imposed under section 271DA of the Act due to the absence of recorded satisfaction in the quantum assessment order, a mandatory prerequisite for levying such penalty. Drawing analogy from the Supreme Court's ruling in a case concerning section 271E, where penalties were quashed for lack of recorded satisfaction, the tribunal held that the same principle applies to penalties under section 271DA. Consequently, the penalty imposed without the requisite satisfaction recording was held invalid. The appeal filed by the assessee was allowed, and the penalty under section 271DA was cancelled.
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