https://www.taxtmi.com/caselaws?id=460194 ITAT Hyderabad held that penalty under section 271D cannot be levied without recording satisfaction in the assessment order. The tribunal ruled that assessment proceedings must be pending for penalty initiation under sections 271D/271E, following precedents from Umakant Sharma and Vijayaben G. Zalavadia cases. Applying the Supreme Court decision in Jai Laxmi Rice Mills, the tribunal emphasized that satisfaction must be recorded in the original assessment order before initiating penalty proceedings. The penalty was deleted in favor of the assessee. en-us Mon, 18 Dec 2023 00:00:00 +0530 Tue, 14 Jan 2025 19:59:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460194 ITAT Hyderabad held that penalty under section 271D cannot be levied without recording satisfaction in the assessment order. The tribunal ruled that assessment proceedings must be pending for penalty initiation under sections 271D/271E, following precedents from Umakant Sharma and Vijayaben G. Zalavadia cases. Applying the Supreme Court decision in Jai Laxmi Rice Mills, the tribunal emphasized that satisfaction must be recorded in the original assessment order before initiating penalty proceedings. The penalty was deleted in favor of the assessee. Case-Laws Income Tax Mon, 18 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460194