2026 (7) TMI 42

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....pi Nath Chaubey, Ld. Sr. DR ORDER :: PER, SHRI SONJOY SARMA, JM: The assessee is in appeal against the order passed by the National Faceless Appeal Centre (hereinafter referred to as "NFAC") dated 09.02.2026, confirming the penalty imposed under section 271D of the Income Tax Act,1961(hereinafter referred to as "Act") arising out of penalty order passed under section 271D of the Act dated....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....nalty order has been passed. During the course of penalty proceedings, the assessee submitted that the amount of Rs. 15,00,000/- represented consideration received on sale of a trailer. However, the assessee failed to furnish supporting documents such as purchase/sale documents or relevant vouchers in support of the claim. Accordingly, the Assessing Officer imposed a penalty of Rs. 15,00,000/- und....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....tsoever regarding initiation of penalty proceedings under section 271D of the Act in the body of the Assessment order. Reliance was placed on the judgment of the Hon'ble Supreme Court in the case of CIT vs. Jai Laxmi Rice Mills, Ambala City, 64 taxman.com 75 (SC) wherein it was held that in the absence of satisfaction recorded by the Assessing Officer regarding initiation of penalty proceedings, s....