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2021 (9) TMI 1535 - AT - Income TaxPenalty u/s 271D - allegation of non recording of satisfaction by AO before initiation of any penalty - HELD THAT:- As perused the assessment order passed by the AO the assessment order is conspicuously silent on recording of any satisfaction by the assessing officer for the purpose of initiative the penalty u/s 271D. In our considered opinion the recording of satisfaction by the AO is essential for initiation of any penalty u/s 271D of the act and failure to record, the satisfaction in the manner provided by the law and more particularly in the light of the judgement, is fatal, and accordingly the penalty proceedings initiated against the assessee by the assessing officer and confirmed by the CIT(A) are required to be quashed - Appeal of assessee allowed.
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