https://www.taxtmi.com/caselaws?id=449126 ITAT Raipur dismissed revenue's appeal challenging penalty deletion under sections 271D and 271E. The tribunal held that penalty proceedings, though independent of assessment proceedings, cannot be sustained without proper satisfaction recorded during reassessment under sections 147, 144, and 144B. Following SC precedent in CIT vs. Jai Laxmi Rice Mills, the tribunal upheld CIT(A)'s finding that penalties imposed without requisite satisfaction in underlying reassessment are unsustainable. The case involved allegations of accepting loans through journal entries violating section 269SS. en-us Wed, 31 Jan 2024 00:00:00 +0530 Tue, 06 Feb 2024 20:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449126 ITAT Raipur dismissed revenue's appeal challenging penalty deletion under sections 271D and 271E. The tribunal held that penalty proceedings, though independent of assessment proceedings, cannot be sustained without proper satisfaction recorded during reassessment under sections 147, 144, and 144B. Following SC precedent in CIT vs. Jai Laxmi Rice Mills, the tribunal upheld CIT(A)'s finding that penalties imposed without requisite satisfaction in underlying reassessment are unsustainable. The case involved allegations of accepting loans through journal entries violating section 269SS. Case-Laws Income Tax Wed, 31 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449126