https://www.taxtmi.com/caselaws?id=754206 The ITAT Chennai allowed the assessee's appeal and deleted the penalty levied under section 271D. The tribunal found the penalty notice fundamentally defective as the JCIT initially initiated proceedings under section 271DA in January 2022 but later corrected to section 271D just 13 days before imposing penalty. This procedural error violated Article 14 and denied the assessee fair hearing rights under section 274. The tribunal held that sections 271D and 271DA are distinct provisions with different applications, and the defective notice vitiated all subsequent proceedings, making the penalty legally unsustainable. en-us Wed, 29 May 2024 00:00:00 +0530 Tue, 18 Jun 2024 09:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754206 The ITAT Chennai allowed the assessee's appeal and deleted the penalty levied under section 271D. The tribunal found the penalty notice fundamentally defective as the JCIT initially initiated proceedings under section 271DA in January 2022 but later corrected to section 271D just 13 days before imposing penalty. This procedural error violated Article 14 and denied the assessee fair hearing rights under section 274. The tribunal held that sections 271D and 271DA are distinct provisions with different applications, and the defective notice vitiated all subsequent proceedings, making the penalty legally unsustainable. Case-Laws Income Tax Wed, 29 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754206