SHAIKH SUJAYAT SHAIKH ISLAM,AMRAVATI vs. ITO WARD-3, AMRAVATI

ITA 416/NAG/2026Status: DisposedITAT Nagpur11 September 2026AY 2017-184 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that penalty proceedings under Section 271D are invalid if not initiated after recording proper satisfaction during assessment proceedings. Since no assessment proceedings were initiated and no valid satisfaction was recorded by the Assessing Officer, the penalty was quashed.

What were the facts?

The assessee appealed against a penalty order of Rs. 12,10,000/- imposed under Section 271D of the Income Tax Act for Assessment Year 2017-18. The penalty was levied for alleged violation of Section 269SS, relating to cash transactions.

What were the issues?

Whether penalty under Section 271D can be levied without prior assessment proceedings and recording of satisfaction by the Assessing Officer.

Which sections of the Income-tax Act were involved?

Section 271D,Section 269SS,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, NAGPUR SMC BENCH, NAGPUR

Before: SHRI MANISH BORAD

For Appellant: Shri K.P. Dewani, Advocate
For Respondent: Ms. Jaya Lakhwani, Sr.DR
Hearing: 03/08/2026Pronounced: 11/09/2026

This appeal by the assessee is directed against the order of Ld. Commissioner of Income Tax (Appeals)/NFAC, Delhi (for short, “CIT(A)”) dated 26.02.2026 passed u/sec. 250 of the Income Tax Act, 1961 (for short, “Act”) which is arising out of penalty order dated 19.11.2019 passed u/sec. 271D of the Act passed by the Addl./JCIT, Range-Amravati, for the Assessment Year (A.Y.) 2017-18. 2. Sole grievance of the assessee revolves around to the penalty order passed u/sec. 271D of the Act at Rs. 12,10,000/-

3(a) At the outset, learned counsel for the assessee, referring to plethora of decisions, has submitted that the impugned penalty deserves to be deleted as there is no valid satisfaction for initiation of penalty proceedings recorded durin

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 271D

All 1,725 judgments and leading authorities on Section 271D →

Latest GST High Court judgments

Search GST case law →