PUSAPATI SUDHAKAR REDDY,GUNTUR vs. ACIT, CENTRAL CIRCLE-2, GUNTUR

ITA 30/VIZ/2026Status: DisposedITAT Visakhapatnam19 August 2026AY 2021-2227 pages
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What did the Tribunal hold?

The Tribunal held that the mandatory condition of recording satisfaction by the Assessing Officer in the assessment order for initiating penalty proceedings under Section 271D was not met. Furthermore, the penalty order was found to be barred by limitation.

What were the facts?

The assessee's appeal challenges a penalty order under Section 271D of the Income Tax Act. The assessee argued that the penalty proceedings were initiated without proper satisfaction recorded by the Assessing Officer and were also barred by limitation.

What were the issues?

Whether the penalty under Section 271D was validly initiated without recording satisfaction and whether it was within the prescribed limitation period.

Which sections of the Income-tax Act were involved?

Section 271D,Section 275

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, VISAKHAPATNAM DB BENCH VISAKHAPATNAM

Before: SHRI VIJAY PAL RAO & SHRI MANJUNATHA G.

Hearing: 11.08.2026Pronounced: 19.08.2026

PER VIJAY PAL RAO, VICE PRESIDENT :

This appeal by the Assessee is directed against the Order dated 16.09.2025 of the learned CIT(A), Visakhapatnam-3, Visakhapatnam arising from the penalty order passed by the Assessing Officer u/sec.271D of the 2 ITA.No.30/Viz./2026 Income Tax Act [in short "the Act"], 1961 for the assessment year 2021-2022. 2. The assessee has raised the following grounds of appeal: 1. “The order passed by the Learned CIT (Appeals) is against the law as well as on the facts of the case.

2.

On the facts and circumstances of the case, the Learned CIT(Appeals) erred in upholding the le

The order continues below.

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