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ITAT held that recording of satisfaction by the AO is a condition precedent to initiate penalty proceedings under s.271D for alleged contravention of s.269SS, and where the AO's satisfaction was embodied in the assessment order dated 30-12-2022 after statutory approval by the Addl. CIT, that date constitutes the date on which "action for imposition of penalty is considered as initiated" for purposes of s.275(1)(c). Applying the prescribed limitation, the penalty order had to be passed by 30-06-2023; the impugned penalty dated 31-08-2023 was therefore time-barred and held non est. The penalty order is quashed.
ITAT held that recording of satisfaction by the AO is a condition precedent to initiate penalty proceedings under s.271D for alleged contravention of s.269SS, and where the AO's satisfaction was embodied in the assessment order dated 30-12-2022 after statutory approval by the Addl. CIT, that date constitutes the date on which "action for imposition of penalty is considered as initiated" for purposes of s.275(1)(c). Applying the prescribed limitation, the penalty order had to be passed by 30-06-2023; the impugned penalty dated 31-08-2023 was therefore time-barred and held non est. The penalty order is quashed.
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