2026 (7) TMI 563

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.... Gopi Nath Chaubey, Ld. Sr. DR ORDER PER, SHRI SONJOY SARMA, JM: This appeal is filed by the assessee against the order dated 09.02.2026 passed by the National Faceless Appeal Centre (NFAC), confirming the penalty imposed under Section 271E of the Income Tax Act, 1961 arising from penalty order dated 26.09.2024. 2. Brief facts of the case are that the assessee had declared total busine....

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....suing notice under Section 274 read with Section 271E of the Act. Thereafter, penalty order dated 26.09.2024 was passed imposing penalty of Rs.60,00,000 upon the assessee. 3. Aggrieved by the same, the assessee preferred an appeal before the CIT(A). However, the appellate authority sustained the penalty imposed under Section 271E of the Act by rejecting the appeal of the assessee. 4. Being a....

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....ered by the decision of the Hon'ble Supreme Court in CIT vs. Jai Laxmi Rice Mills, Ambala City (2015) 64 taxman.com.75(SC), wherein it has been held that in the absence of satisfaction recorded regarding initiation of penalty proceedings in the body of the assessment order, such proceedings cannot survive. 5. On the other hand, the Ld. DR relied upon the orders of the lower authorities. However....