https://www.taxtmi.com/caselaws?id=775438 The ITAT Delhi held that the levy of penalty under section 271DA requires recording of satisfaction by the AO. Following the SC ruling in CIT v. Jai Laxmi Rice Mills, where absence of recorded satisfaction in the assessment order led to cancellation of penalty under section 271E, the same principle was applied to section 271DA. Since no satisfaction was recorded in the quantum assessment order, the penalty under section 271DA could not be sustained. The penalty was accordingly cancelled and the assessee's appeal was allowed. en-us Wed, 23 Jul 2025 00:00:00 +0530 Fri, 25 Jul 2025 08:28:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775438 The ITAT Delhi held that the levy of penalty under section 271DA requires recording of satisfaction by the AO. Following the SC ruling in CIT v. Jai Laxmi Rice Mills, where absence of recorded satisfaction in the assessment order led to cancellation of penalty under section 271E, the same principle was applied to section 271DA. Since no satisfaction was recorded in the quantum assessment order, the penalty under section 271DA could not be sustained. The penalty was accordingly cancelled and the assessee's appeal was allowed. Case-Laws Income Tax Wed, 23 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775438