Penalty under section 271D was held impermissible while the...

Penalty under section 271D was held impermissible while the assessment order was under challenge before a statutory appellate forum; the court reasoned that penalty proceedings should be kept in abeyance pending the outcome of quantum proceedings and accordingly set aside the impugned penalty order. The court relied on prior precedent to conclude that initiation or finalisation of penalty proceedings during subsistence of a quantum appeal defeats orderly adjudication; consequence: penalty order dated 9 December 2025 was quashed and penalty proceedings directed to be stayed until the quantum appeal is decided.