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2016 (2) TMI 1206 - ITAT BANGALORELevy of penalty u/s 271E and 271D - non recording of satisfaction - Held that:- It is imperative for satisfaction to be recorded in the assessment order for initiation of penalty u/s 271E of the Act. Proceedings u/s 271D of the IT Act, also in our opinion will stand on the very same footing. If satisfaction has to be recorded with respect to proceedings u/s 271E of the IT Act, similar satisfaction has to be recorded for the proceedings u/s 271D of the IT Act, 1961 also. These have not been done in the case before us. Accordingly, by virtue of judgment of the Hon’ble Apex Court in the case of CIT Vs Jai Laxmi Rice Mills [2015 (11) TMI 1453 - SUPREME COURT] we are of the opinion, that the levy of penalty u/s 271D & 271E of the IT Act, 1961 cannot survive. Such orders are set aside and the appeals of the assessee are allowed
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