https://www.taxtmi.com/caselaws?id=765692 The HC ruled that penalty proceedings under Section 271E of the Income Tax Act, 1961, were invalid due to the lack of recorded satisfaction by the Assessing Officer (AO) during reassessment proceedings. The Court emphasized the necessity of AO's satisfaction as part of the assessment process, aligning with the precedent set by the SC in Jai Laxmi Rice Mills. The satisfaction recorded by the Additional Commissioner of Income Tax (ACIT) post-reassessment was deemed insufficient. Consequently, the Court quashed the penalty notices issued under Section 271E and allowed the writ petitions, invalidating the penalty proceedings. en-us Thu, 30 Jan 2025 00:00:00 +0530 Fri, 07 Feb 2025 08:38:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765692 The HC ruled that penalty proceedings under Section 271E of the Income Tax Act, 1961, were invalid due to the lack of recorded satisfaction by the Assessing Officer (AO) during reassessment proceedings. The Court emphasized the necessity of AO's satisfaction as part of the assessment process, aligning with the precedent set by the SC in Jai Laxmi Rice Mills. The satisfaction recorded by the Additional Commissioner of Income Tax (ACIT) post-reassessment was deemed insufficient. Consequently, the Court quashed the penalty notices issued under Section 271E and allowed the writ petitions, invalidating the penalty proceedings. Case-Laws Income Tax Thu, 30 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765692