MANEMMA POLU,HYDERABAD vs. ITO, WARD 9(1), HYDERABAD

ITA 1611/HYD/2026Status: DisposedITAT Hyderabad23 September 2026AY 2017-1810 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the penalty proceedings under Section 271D were not sustainable because the AO had not recorded the requisite satisfaction in the assessment order before initiating such proceedings. The Tribunal relied on the Supreme Court's decision in CIT Vs. Jai Laxmi Rice Mills.

What were the facts?

The assessee deposited a significant amount of cash in her bank account during the demonetization period, which she explained as sale consideration from a land transaction. The Assessing Officer (AO) initiated penalty proceedings under Section 271D for alleged violation of Section 269SS regarding cash receipts.

What were the issues?

Whether penalty under Section 271D is valid without the AO recording satisfaction during assessment proceedings. Whether cash received as sale consideration for immovable property violates Section 269SS.

Which sections of the Income-tax Act were involved?

Section 271D,Section 269SS,Section 273B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Hyderabad ‘ SMC ‘ Bench, Hyderabad

PER MANJUNATHA G., A.M : This appeal filed by the assessee is directed against the order of the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre [in short “NFAC”], Delhi, dated 06.02.2026, pertaining to the assessment year 2017-18. 2. Brief facts of the case are that, the as

The order continues below.

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