https://www.taxtmi.com/caselaws?id=451098 ITAT Chennai dismissed revenue's appeals challenging deletion of penalties under sections 271D and 271E. The assessee faced penalties for alleged cash loan receipts and interest payments violating sections 269SS and 269T. The AO failed to record satisfaction before initiating penalty proceedings under section 271D, violating CBDT Circular 09/DV/2016. Additionally, there was a three-year gap between assessment completion and penalty initiation, exceeding statutory time limits. CIT(A) correctly deleted penalties for both assessment years 2015-16 and 2016-17, following precedents including Jai Laxmi Rice Mills. Since sections 271D and 271E are in pari materia, separate adjudication for section 271E was unnecessary. en-us Wed, 13 Mar 2024 00:00:00 +0530 Wed, 20 Mar 2024 09:18:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=451098 ITAT Chennai dismissed revenue's appeals challenging deletion of penalties under sections 271D and 271E. The assessee faced penalties for alleged cash loan receipts and interest payments violating sections 269SS and 269T. The AO failed to record satisfaction before initiating penalty proceedings under section 271D, violating CBDT Circular 09/DV/2016. Additionally, there was a three-year gap between assessment completion and penalty initiation, exceeding statutory time limits. CIT(A) correctly deleted penalties for both assessment years 2015-16 and 2016-17, following precedents including Jai Laxmi Rice Mills. Since sections 271D and 271E are in pari materia, separate adjudication for section 271E was unnecessary. Case-Laws Income Tax Wed, 13 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=451098