Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
ITAT allowed the appeal and set aside the penalty proceedings under s.271D. The Tribunal held that valid initiation of penalty under s.271D requires the Assessing Officer to record a satisfaction in the assessment order that a transaction contravenes s.269SS; such satisfaction is mandatory. In the present assessment under s.153C, the AO did not record any satisfaction regarding contravention of s.269SS. Consequently, the penalty proceedings were held invalid for lack of statutory satisfaction, and the levy of penalty under s.271D could not be sustained against the assessee.
ITAT allowed the appeal and set aside the penalty proceedings under s.271D. The Tribunal held that valid initiation of penalty under s.271D requires the Assessing Officer to record a satisfaction in the assessment order that a transaction contravenes s.269SS; such satisfaction is mandatory. In the present assessment under s.153C, the AO did not record any satisfaction regarding contravention of s.269SS. Consequently, the penalty proceedings were held invalid for lack of statutory satisfaction, and the levy of penalty under s.271D could not be sustained against the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
