LATE SHRI SATHEESAN VASU REPRESENTED BY SMT. JANAKI RAGINI WIFE AND LEGAL HEIR,PEDAGANTYADA vs. ITO, WARD - 5(3), VISAKHAPATNAM

ITA 328/VIZ/2026Status: DisposedITAT Visakhapatnam09 September 2026AY 2016-179 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the AO failed to record the requisite satisfaction in the assessment order before initiating penalty proceedings under Section 271D. Consequently, the penalty order was deemed invalid.

What were the facts?

The assessee allegedly received sale consideration of Rs. 14,82,000/- in cash for a property sale, violating Section 269SS. The Assessing Officer (AO) levied a penalty under Section 271D, which was upheld by the CIT(A).

What were the issues?

Whether a penalty under Section 271D is valid if the AO does not record satisfaction in the assessment order for the violation of Section 269SS.

Which sections of the Income-tax Act were involved?

Section 271D,Section 269SS,Section 274

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, VISAKHAPATNAM BENCH, VISAKHAPATNAM

Pronounced: 09.09.2026

PER MANJUNATHA G., ACCOUNTANT MEMBER :

This appeal is filed by the Assesseeagainst the order of the Commissioner of Income Tax(Appeals) [“Ld.CIT(Appeals)”], National Faceless Appeal Centre (“NFAC”), Delhi vide DIN & Order

1 Late Shri Satheesan Vasu represented by Smt. Janaki Ragini, wife and legal heir No.ITBA/NFAC/S/250/2025-26/1085327228(1)dated 30.01.2026for the Assessment Year 2016-17, arising out of pen

The order continues below.

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