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2024 (2) TMI 277 - AT - Income TaxValidity of Penalty u/s 271D and u/s 271E - Penalty proceeding as independent of the assessment proceeding - absence of satisfaction recorded in the reassessment u/s 147 r.w.s 144 r.w.s. 144B - allegation of acceptance of loans through journal entries as violative of section 269SS - HELD THAT:- Issue before us is no more res-integra in light of the judgment in the case of CIT vs. Jai Laxmi Rice Mills, Ambala City (2015 (11) TMI 1453 - SUPREME COURT] therefore, the penalty imposed by Ld. JCIT u/s 271D of the Act, dehors any satisfaction recorded in the reassessment u/s 147 r.w.s 144 r.w.s. 144B by the concerned AO, is not sustainable, thus, we concur with the findings of Ld. CIT(A) which is on the same line as discussed hereinabove, therefore, we do not find any infirmity in the order of Ld. CIT(A) to be interfered with. In the result, appeal of the revenue stands dismissed.
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