https://www.taxtmi.com/highlights?id=78107 The ITAT Delhi held that the levy of penalty u/s 271D without valid satisfaction for alleged violation u/s 269SS is not justified. The AO must record satisfaction in the assessment order u/s 143(3) to initiate penalty proceedings u/s 271D. In this case, the AO failed to record satisfaction for penalty u/s 271D for the relevant assessment years. The tribunal referred to the case law of Jai Laxmi Rice Mills and concluded that penalty u/s 271D was not warranted. Consequently, the penalty imposed u/s 271D for both assessment years was deleted, and the appeals of the assessee were allowed. en-us Tue, 04 Jun 2024 08:04:16 +0530 Tue, 04 Jun 2024 08:04:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=78107 The ITAT Delhi held that the levy of penalty u/s 271D without valid satisfaction for alleged violation u/s 269SS is not justified. The AO must record satisfaction in the assessment order u/s 143(3) to initiate penalty proceedings u/s 271D. In this case, the AO failed to record satisfaction for penalty u/s 271D for the relevant assessment years. The tribunal referred to the case law of Jai Laxmi Rice Mills and concluded that penalty u/s 271D was not warranted. Consequently, the penalty imposed u/s 271D for both assessment years was deleted, and the appeals of the assessee were allowed. Highlights Income Tax Tue, 04 Jun 2024 08:04:16 +0530 https://www.taxtmi.com/highlights?id=78107