2025 (2) TMI 238

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....)<br>RAJASTHAN HIGH COURT - HC (Judgement / Order / Decisions)<br>Dated:- 30-1-2025<br>D. B. Civil Writ Petition No. 1102/2025 AND OTHER - -<br>Income Tax<br>D. B. Civil Writ Petition No. 1102/2025 D.B. Civil Writ Petition No. 1129/2025 &nbsp;D.B. Civil Writ Petition No. 1156/2025 D.B. Civil Writ Petition No. 1264/2025 D.B. Civil Writ Petition No. 15159/2024 D.B. Civil Writ Petition No. 12783/202....

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....rabh Harsh , Adv For the Respondent : Mr.Siddharth Bapna, Adv., Mr.Sarvesh Jain, Adv., Mr.Meyhul Mittal, Adv. & Mr.Rahul Kumar , Adv ORDER AVNEESH JHINGAN , J ( ORAL ) : - 1. These writ petitions are being decided by this order as the facts and issues involved are same. Though in some of the cases penalty under Section 271D and in others under Section 271E of the Income Tax Act, 1961 (....

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....). On 01.10.2024 notice was issued to the petitioner for imposition of penalty under Section 271E of the Act of 1961. In the response dated 16.10.2024 the petitioner relied upon the decision of the Supreme Court in Commissioner of Income Tax Vs. Jai Laxmi Rice Mills reported in [(2015) 379 ITR 521 (SC)] to contend that there was no satisfaction recorded in the reassessment order for initiating the....

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....the ACIT on 24.09.2024 recorded the satisfaction. It is argued that there is no requirement under section 271E for assessing officer (hereinafter 'AO') to record the satisfaction. The counsel is not able to distinguish the citation relied upon by counsel for the petitioner. 6. The reassessment order was passed on 12.03.2024 and no satisfaction was recorded for initiating the penalty proceedings....